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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.
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