- 2 - 6651(a)(1) addition to tax, and a $7,075 section 6662(a) accuracy- related penalty. All section references are to the Internal Revenue Code as in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. These cases were consolidated for trial, briefing, and opinion. The issues for decision are: (1) Whether petitioners had $106,000 of unreported income in 1991; and (2) if so, then (a) whether petitioner Mercedes Arcia (Mrs. Arcia) qualifies as an innocent spouse pursuant to section 6013(e); (b) whether petitioners are liable for the section 6651(a)(1) addition to tax for 1991; and (c) whether petitioners are liable for the section 6662(a) accuracy-related penalty for 1991. 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. Elio and Mercedes Arcia, husband and wife, resided in Miami, Florida, at the time they filed their respective petitions in these cases. Eduardo Macias and His Friends Eduardo Macias, born in Cuba but living in the United States at all relevant times, served time in a U.S. prison between 1983Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011