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(3) Whether petitioners are liable for section 6662(a)
accuracy-related penalties on account of negligence, for the
taxable years 1992 through 1995.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue, and 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 stipulations filed by the parties, with accompanying
exhibits, are incorporated herein by this reference.
Ralph E. and Catherine R. Wesinger (petitioners) are married
and resided in Livermore, California, when they filed their
petitions. However, because no evidence was presented as to Mrs.
Wesinger’s involvement in the ranching and rental operations, our
discussion of these activities will focus upon Mr. Wesinger
(petitioner).
Petitioner was born and raised in Concord, Massachusetts.
He then attended the University of Massachusetts for 2 years and
took courses in computer science and general liberal arts, but he
did not earn a degree. Shortly after leaving the University of
Massachusetts, he was hired by Digital Equipment Corporation
(Digital). Petitioner remained with Digital for approximately 4
years and during that time worked as a computer systems
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