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negligence or disregard of rules or regulations or for the
substantial understatement of their 1991 income tax. We hold
petitioners are liable for the penalty for negligence or
disregard of rules or regulations.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. At the time the petition
in this case was filed, petitioners resided in Kerman,
California.
FINDINGS OF FACT
In the second half of the 1980's, petitioner was frequently
away from home while working in the construction industry.
Petitioner thought that it would be more economical to buy a used
Greyhound bus and convert it into a motor home, which he would
live in when he was working away from home, than to pay for
commercial lodging and food. Accordingly, in March 1985,
petitioners purchased a previously owned 1962 GMC Coach (bus) for
$14,359.
The bus required repairs to the clutch and transmission,
which were made shortly after purchase. The first item that
petitioners purchased as part of the conversion process was a
generator. During 1985, petitioner painted the body, completed
the bedroom, and added wood paneling, lights, curtains, chairs, a
couch, and bathroom plumbing, including holding tanks for potable
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