- 2 -
1989 179,964 44,991
1990 14,324 3,581
Unless stated otherwise, all section references are to the
Internal Revenue Code as in effect for the years in issue.
After concessions, the issue for decision is whether
petitioners are liable for additions to tax under section
6651(a)(1) for failure to file timely income tax returns
for 1988 and 1989.
FINDINGS OF FACT
Some of the facts have been stipulated and are so
found. The stipulation of facts and the exhibits attached
thereto are incorporated herein by this reference.
Petitioners are husband and wife who filed joint individual
income tax returns for 1988, 1989, and 1990. At the time
the petition was filed in this case, petitioners resided
in Corpus Christi, Texas. In this opinion, references to
petitioner are to Mr. William O. Harrison, Jr.
Petitioner received a bachelor's degree in 1967 from
Texas Christian University where he majored in history. He
received a law degree in 1970 from the University of Texas
Law School where, among other courses, he took a tax course
and a required course in legal accounting. After
graduating from law school, petitioner was employed from
1971 through 1975 by a law firm in Corpus Christi, Texas.
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