Richard and Rebecca Adair - Page 2




                                        - 2 -                                         
                                       Fraud Penalty                                 
          Year     Deficiency       Sec. 6663                                         
          1993                $192,142          $144,107                              
          1994                185,261         138,946                                 
          1995     123,633            92,725                                          

               Unless otherwise indicated, all section references are to              
          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.                                                                  
               The issues for decision involve the amount of unreported               
          income that should be charged to petitioners and petitioners’               
          liability under section 6663 for the fraud penalty.  Hereinafter            
          all references to petitioner are to Rebecca Adair.                          

                                  FINDINGS OF FACT                                    
               Because petitioners failed to respond to respondent's                  
          requests for admission, factual matters set forth in respondent's           
          requests for admission are deemed admitted.  See Rule 90(c).                
               When the petition was filed, petitioners resided in Clinton,           
          Louisiana.  Petitioners and Delwin Houser, Rebecca Adair’s step-            
          father, operate a roofing business known as H & H Sheet Metal               
          (the roofing business).  The evidence does not establish how                
          ownership of the roofing business is divided between petitioners            
          and Delwin Houser.                                                          










Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011