- 3 -
4. Whether petitioners are liable for the substantial
understatement additions to tax under section 6661.
5. If petitioner Dwight L. McKenna is not liable for the
fraud additions to tax, whether petitioners are liable for the
negligence additions to tax.
6. Whether the assessment of petitioners' Federal income
taxes for 1987 is barred by the statute of limitations.
FINDINGS OF FACT
Some of the facts are stipulated and are so found. The
stipulations of facts and the exhibits attached thereto are
incorporated herein by this reference.
Petitioners Dwight L. McKenna and Beverly S. McKenna resided
in New Orleans, Louisiana, at the time they filed their petition
in this case. Their joint Federal income tax returns for 1987
and 1988 were filed with the Internal Revenue Service on August
15, 1988, and September 5, 1989, respectively.
Dwight L. McKenna's Background
Dwight L. McKenna (hereinafter petitioner) was born and
raised in New Orleans. He attended elementary, high school, and
college there. He received his medical training at Meharry
Medical College in Nashville, Tennessee, from which he graduated
in 1966. He interned at the University of Missouri, Kansas City
General Hospital, and later took his residency in surgery at
Howard University in Washington, D.C. After a tour of duty as a
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