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and if so, (2) whether petitioner is liable for the section 6662(a)
accuracy-related penalty.
All section references are to the Internal Revenue Code as in
effect for the year under consideration. All Rule references are
to the Tax Court Rules of Practice and Procedure.
Background1
At the time he filed his petition, petitioner resided in
Brookshire, Texas. Petitioner and his wife, Maria, filed separate
Federal income tax returns for 1993.
Petitioner was born and raised in Mercedes, Texas, which is
located between Brownsville, Texas, and the Mexican border.
Mercedes is approximately 320 miles south of Brookshire.
Harlingen, Texas, a suburb of Mercedes, is located approximately 20
to 25 miles north of the Mexican border.
During 1993, petitioner was a self-employed truck driver,
hauling rock, sand, and gravel for road building and housing sites.
Abel
Petitioner testified that (approximately 12 years ago) he met
an individual he knew only as Abel at a "beer joint" in Mercedes;
they became friends and customarily (approximately once a week)
drank beer and played pool. Petitioner did not know where Abel
1 Some of the facts have been stipulated and are found
accordingly. The stipulations of facts and the exhibits
submitted therewith are incorporated herein by this reference.
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