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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 1983
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