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4. Whether petitioner is liable for penalties for
negligence under section 6662 for 1993 and 1994. We hold that he
is.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect during the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
I. FINDINGS OF FACT
A. Petitioner
1. Petitioner and Ms. Jones-George
Petitioner lived in Arizona when he filed his petition.
Petitioner and Jaye Jones-George (Jones-George) were married
from September 1989 to June 1994. In 1993, they owned and lived
in a residence in Scottsdale, Arizona (the Scottsdale residence).
Petitioner was not married at the time of trial.
During 1993, petitioner had a personal bank account at the
Bank of America.
2. Petitioner's Medical Practice
Petitioner has a bachelor of science degree in Zoology from
the University of Michigan and a Doctor of Osteopathy (D.O.)
degree from the Chicago College of Osteopathic Medicine. He
completed a residency in Biomechanics at Michigan State
University.
At the time of trial, petitioner had been an osteopathic
physician for 15 years and a homeopathic physician for 4 years.
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