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(6) whether petitioner is liable for the addition to tax
pursuant to section 6661 for 1984; and
(7) whether petitioner is liable for the addition to tax
pursuant to section 6659 for 1985.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed his
petition in docket Nos. 4449-92 and 5744-92, petitioner (Mr.
Davis) resided in Amlin, Ohio. At the time he filed his petition
in docket No. 25088-96, petitioner resided in Tampa, Florida.
Mr. Davis' Professional Activities
Mr. Davis was born on October 31, 1938, in Columbus, Ohio.
In his youth, he often chauffeured his mother, a real estate
agent, around Columbus in connection with her business. Mr.
Davis observed his mother attentively and learned about real
estate. As his knowledge increased, he grew anxious to enter the
real estate business. In February 1955, Mr. Davis applied for,
and received, a real estate license.
Initially, Mr. Davis actively and successfully sold
residential real properties. Soon thereafter, his emphasis
shifted from selling real estate to constructing, remodeling, and
developing real estate. Originally, this business operated as a
sole proprietorship. Gradually, the business expanded, and Mr.
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