Robert E. Dunham - Page 3

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          either section 6651(a)(1) or section 6651(f), and under section             
          6654 for the years in issue; and (5) whether a penalty should be            
          awarded under section 6673.  Respondent has conceded that                   
          petitioner is not liable for section 6662(a) accuracy-related               
          penalties as determined in the notice of deficiency for 1989 and            
          as alleged in the Amendment to the Answer for 1990, 1991, and               
          1992.                                                                       
                                  FINDINGS OF FACT2                                   
               At the time the petition was filed, petitioner resided in              
          Crossett, Arkansas.  During the years in issue, petitioner was a            
          veterinarian in a sole proprietorship doing business as the                 
          Crossett Animal Clinic.  Petitioner received adjusted gross                 
          income from his veterinary practice of $65,000 in each of the               
          years in issue.  In 1992, petitioner had a short-term capital               
          gain of $752.50 from the sale of stock.  In 1992, petitioner also           
          received interest income of $35 and dividend income of $65.                 
          Petitioner failed to report the income from his veterinary                  
          practice, the capital gain, or the interest and dividend income,            
          or to pay Federal income taxes on these amounts.  In 1989,                  
          petitioner received a $30,000 premature distribution from his               
          individual retirement account (IRA).                                        



               2 The stipulation of facts and the attached exhibits are               
          incorporated therein by this reference.                                     





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