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whether petitioners in docket Nos. 22011-97 and 22012-97 (the
Fieldses and the Bullocks) are liable for additions to tax pursuant
to section 6651(a)(1) for failure to timely file a return; and (4)
whether petitioners are liable for the accuracy-related penalty
pursuant to section 6662(a).
All section references are to the Internal Revenue Code as in
effect for the years under consideration. All Rule references are
to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
Petitioners Alfred L. and Renee E. Fields, husband and wife,
(the Fieldses) resided in Chesapeake, Virginia, at the time they
filed their petition contesting respondent's determinations. The
Fieldses filed their 1993 and 1994 Federal income tax returns late.
Petitioners Frank H. and Irma E. Bullock, husband and wife,
(the Bullocks), Leroy and Mattrude P. Sharpe, husband and wife,
(the Sharpes), and Esker L. Peacock (Mr. Peacock) all resided in
Portsmouth, Virginia, at the time they filed their respective
petitions contesting respondent's determinations. The Bullocks
timely filed their 1993 Federal income tax return but filed their
1994 return late. Both the Sharpes and Mr. Peacock timely filed
their 1993 and 1994 Federal income tax returns.
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Last modified: May 25, 2011