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Respondent determined deficiencies in Federal individual
income tax and additions to tax under section 6662 (accuracy-
related) against petitioners as follows:
Additions to Tax
Year Deficiency Sec. 6662
1991 $356,117 $71,223
1992 470,966 94,193
Background
When the petition was filed in the instant case, petitioners
Robert M. Maddox (hereinafter sometimes referred to as Robert)
and Paulette G. Maddox (hereinafter sometimes referred to as
Paulette), husband and wife, resided in El Paso, Texas.
Businesses
Robert is an ophthalmologist with a medical practice in El
Paso, Texas. In 1991, Robert opened another ophthalmology office
in Juarez, Mexico, which allowed him to perform a type of laser
eye surgery that was not permitted in the United States at that
time.
Robert had extensive business interests in addition to his
medical practice. He was the sole shareholder of several S
corporations, some of which related to his medical practice.
Others involved a restaurant, a farm, and real estate interests.
El Paso to Dallas
Petitioners filed individual income tax returns for 1991 and
1992. The tax returns were mailed, in accordance with extensions
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