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After concessions, the issues for decision are:
1. Whether petitioners are liable for additions to tax for
failure to file timely returns under section 6651 for 1994 and
1995. We hold that they are.
2. Whether petitioners are liable for an accuracy-related
penalty for negligence under section 6662 for 1994 and 1995. We
hold that they are.
References to petitioner are to Robert C. Watts. Section
references are to the Internal Revenue Code in effect for the
years at issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners lived in San Antonio, Texas, when they filed
their petition.
Petitioner was an architect, and Mrs. Watts was a teacher
during the years in issue. Petitioner worked very long hours
during those years.
Petitioner’s main client was the Church of the Latter Day
Saints. He frequently traveled in Texas during the years in
issue to oversee the building and renovation of churches.
Petitioners’ daughter, Kaye, became seriously ill around May
1994. Petitioner frequently took her to see doctors in 1994 and
1995. She was briefly hospitalized three times in 1994 and 1995.
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