Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 3




                                        - 3 -                                         
               (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                     






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011