James E. and Shirley S. Deas - Page 2




                                        - 2 -                                         
          petitioners are liable for the section 6662 accuracy-related                
          penalty for negligence or disregard of rules or regulations or              
          substantial understatement of income tax.  We find they are                 
          liable for the accuracy-related penalty for negligence.2                    
               Section references are to the Internal Revenue Code in                 
          effect for the taxable year in issue, unless otherwise indicated.           
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  All dollar amounts are rounded to the nearest whole             
          dollar, unless otherwise indicated.  References to petitioner are           
          to James E. Deas.                                                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulated facts and the accompanying exhibits are                      
          incorporated herein by this reference.  At the time the petition            
          in this case was filed, petitioners resided in Heathrow, Florida.           
              In 1985, petitioner and William W. Segrest (Segrest) formed             
         a partnership named Dasco (Dasco or the partnership).  Petitioner            
         and Segrest were general partners, and each owned a 50-percent               
         interest in the partnership.  The partnership's main activity was            

              1(...continued)                                                         
          1992.                                                                       
               2Because we have found that petitioners are liable for the             
          accuracy-related penalty for negligence, we do not consider                 
          whether petitioners are liable for the penalty for the                      
          substantial understatement of income tax.  See sec. 1.6662-2(c),            
          Income Tax Regs.                                                            






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

Last modified: May 25, 2011