- 2 - 1989. Respondent determined deficiencies of $11,253, $15,996, and $14,689 for the respective years. Respondent also determined that petitioners were liable for an $8,440 addition to their 1987 tax under section 6653(b)(1)(A), an $11,997 addition to their 1988 tax under section 6653(b)(1), and an $11,017 penalty for fraud as to 1989. Respondent also determined that petitioners were liable for a time-sensitive addition to their 1987 tax under section 6653(b)(1)(B). We must decide whether petitioners are liable for the deficiencies, additions to tax, and penalty. We hold they are liable for the deficiencies to the extent stated herein and that they are not liable for any of the additions to tax or the penalty. Unless otherwise indicated, section references are to the Internal Revenue Code applicable to the relevant years. Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts have been stipulated. We incorporate herein by this reference the parties’ stipulation of facts and the exhibits submitted therewith. We find the stipulated facts accordingly. Petitioners resided in Charlevoix, Michigan (Charlevoix), when their petition was filed. They filed joint 1987, 1988, and 1989 Federal income tax returns. Michael Barnard (Mr. Barnard) grew up in East Jordan, Michigan. Upon graduating from high school, he attended thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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