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and (2) if that gain is includable in petitioners' 1993 income,
then whether petitioners' failure to report it subjects petitioners
to liability for the section 6662(a) accuracy-related penalty.1
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the year in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulation of
facts is incorporated in our findings by this reference.
Petitioners resided in Ely, Minnesota, at the time they filed their
petition.
Background
Douglass H. Bartley (petitioner) received a bachelor of arts
degree in business administration from the University of Arizona in
1970 and a juris doctor degree from the University of Arizona Law
School in 1973. Petitioner had a private law practice in
Milwaukee, Wisconsin, until 1980; at that time, he moved to
Washington, D.C., and began working at Washington Gaslight Co. In
approximately 1983, he returned to his private practice in
Milwaukee.
1 On May 5, 1998, respondent filed a motion to impose a
sec. 6673 penalty. On July 10, 1998, respondent filed a motion
to withdraw the May 5 motion. On July 14, 1998, we granted
respondent's motion to withdraw the motion to impose a sec. 6673
penalty.
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