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5. Whether petitioners Roland and Virginia Fox are liable
for self-employment tax of $10,658 for 1992 and $11,057 for 1993.
We hold that they are.
6. Whether petitioners Roland and Virginia Fox are liable
for the addition to tax for failure to file under section 6651
for 1993 and the accuracy-related penalty for negligence under
section 6662(a) for 1989, 1992, and 1993. We hold that they are.
7. Whether petitioner Prindle International Marketing is
liable for the addition to tax for failure to file under section
6651 for 1992 and 1993. We hold that it is not.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
A. Roland and Virginia Fox
Roland and Virginia Fox (Mr. and Mrs. Fox) were married in
1980 and lived in Spokane, Washington, when they filed their
petition. They each have three children from prior marriages.
Mr. Fox joined the U.S. Air Force in 1952. He retired in
1972. He received about $22,000 in military retirement pay per
year in 1992 and 1993. He and his family moved to Spokane,
Washington, in November 1973. There he earned a bachelor of arts
degree in Russian history. He also enrolled in a graduate
business administration program at Eastern Washington University,
where he took one tax course. He attended a school for insurance
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