- 3 -
Cir. 1995); Fagan v. City of Vineland, 22 F.3d 1283, 1290 (3d
Cir. 1994); Sanders v. Sullivan, 900 F.2d 601, 605 (2d Cir.
1990). The issues remaining for decision are: (1) Whether any
part of an underpayment of income taxes for 1983 or 1984 is due
to negligence or intentional disregard of rules or regulations;
and if so, (2) whether the portion of the underpayment due to
negligence is eliminated or reduced by petitioners' filing of an
amended return reporting and paying additional income tax for the
taxable year 1983.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
in this case was filed, petitioners were residing in High Point,
North Carolina.
FINDINGS OF FACT
During the years 1983 and 1984, Charles A. Greene
(petitioner) was a limited partner in a partnership known as Mid
Continent Drilling Associates II (Mid Continent or the
partnership). The additions to tax in this case relate to
petitioner’s investment in Mid Continent.
Petitioners' Work and Business History
Petitioner Christine Greene is a high school guidance
counselor.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011