Douglass H. and Suzanne M. Bartley - Page 2

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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         
               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                  

               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            

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