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Year Deficiency Accuracy-Related Penalty
1994 $27,859 $5,572
1995 18,975 3,795
We must decide whether to sustain the determinations in the
notice of deficiency (notice) that respondent has not conceded.
We hold that those determinations should be sustained except to
the extent stated herein.
FINDINGS OF FACT2
Some of the facts have been stipulated and are so found.
Petitioner resided in Phoenix, Arizona, at the time the
petition was filed.
Petitioner, who has a B.S. in engineering, an M.A. in
philosophy, and a law degree, was married to Anne P. Treadaway
(Ms. Treadaway) until she died at the age of 94 on June 12, 1995.
He has two children from that marriage, Penelope Treadaway and
John Treadaway, Jr.
Petitioner and, until she died, Ms. Treadaway lived together
with their son John Treadaway, Jr., in a 5,400-square-foot house
(petitioner’s residence) located at 3140 North 83d Avenue in
Phoenix, Arizona (North 83d Avenue property). Petitioner’s
daughter Penelope Treadaway, her son, and her boyfriend lived in
1(...continued)
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
2Unless otherwise indicated or needed for clarity, our
Findings of Fact and Opinion pertain to the years at issue.
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Last modified: May 25, 2011