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(6) whether petitioner Ramon Ortiz is liable for fraud
penalties under section 6663 for 1991 and 1992;
(7) whether, alternatively, petitioners are liable for the
accuracy-related penalties for 1991 and 1992.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and supplemental stipulation with
attached exhibits are incorporated herein by this reference.
Petitioners Ramon Ortiz (Mr. Ortiz) and Irma Ortiz (Mrs.
Ortiz) resided in Orlando, Florida, at the time they filed their
petition in this case. They were formerly residents of Puerto
Rico, where Mr. Ortiz owned and operated a pharmacy which he sold
in 1987. In July 1988, petitioners moved to Orlando, Florida,
where they purchased a house.
Bank Accounts
During 1991 and 1992 and for prior years, petitioners
maintained a personal checking account at Barnett Bank. Mr.
Ortiz maintained a business checking account in the name of R&X
Auto Sales, a sole proprietorship, at Osceola National Bank.
Sale of Petitioners' House in Puerto Rico
In 1974, petitioners purchased a parcel of land in Puerto
Rico for $18,000. In 1974 or 1975 they had a house built on this
land. Although the record does not show the actual cost of
building the house, petitioners' total investment in the property
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