- 4 -4 for 1989 pursuant to section 6662; (5) whether petitioners are liable for additions to tax for the substantial understatement of tax pursuant to section 6661 for 1986, 1987, and 1988 and for the penalty pursuant to section 6662(b)(2) for 1990; and (6) whether petitioners are liable for the addition to tax for failure to timely file their 1989 joint return pursuant to section 6651(a)(1). All section references are to the Internal Revenue Code as in effect for the years in issue, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Background Petitioners, husband and wife, resided in Lutherville, Maryland, at the time they filed their petition. They were married in 1967 and have one daughter, Nicole. Mr. Zaban graduated from college in 1967 and subsequently became involved in illegal gambling and bookmaking activities (described in detail below). Mrs. Zaban graduated from high school in 1964 and has no college-level education. Between 1986 and 1990, Mrs. Zaban was a homemaker and did not work outside of the home. Mrs. Zaban was the caretaker ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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