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to file a tax return or the addition to tax under section
6654 for failure to pay estimated income tax. Unless
stated otherwise, all section references are to the
Internal Revenue Code as in effect during the years in
issue.
FINDINGS OF FACT
The parties have stipulated some of the facts. The
stipulation of facts filed by the parties and the sole
exhibit attached thereto are incorporated herein by this
reference. Petitioner was a resident of Tulsa, Oklahoma,
at the time he filed his petition in this case.
Petitioner married Sueko Miyasato on February 3, 1971,
in Okinawa, Japan. The couple had four children, Angie
Columbus, Brian Columbus, Christopher Columbus, and
Elizabeth Columbus. At the time the petition was filed in
this case, petitioner was employed by American Airlines,
Inc. During 1992, 1993, and 1994, he received $34,647,
$40,327, and $43,736, respectively, in wages from American
Airlines. Petitioner was formerly a member of the U.S.
Marine Corps. During 1992, 1993, and 1994, he received
$13,154, $13,547, and $13,801, respectively, in taxable
retirement income from the U.S. Marine Corps.
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