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After the parties’ concessions, the only remaining issues
for decision are:
(1) Whether petitioners are liable for the accuracy-related
penalty for taxable year 1995 under section 6662(a); and
(2) whether petitioners are liable for a penalty pursuant to
section 6673.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate the stipulation of facts into these findings by this
reference. Petitioners resided in Shadow Hills, California, at
the time the petition in docket No. 13714-99 was filed.
Walter O. Bowen (petitioner) has been a chiropractor since 1975.
Susan M. Bowen worked in petitioner’s office as a recordkeeper.
Each year, petitioners hired a return preparer to prepare
their income tax returns. Marvin Weisbrod was petitioners’
return preparer for approximately 15 years. After Mr. Weisbrod
passed away, petitioners hired John Gillis to prepare their 1994
tax return.
In 1995, petitioner paid National Trust Services (NTS)
$9,500 to attend a week-long program about trusts. Shortly after
attending the program, petitioners decided to establish two
trusts into which they would transfer their home, business, and
other assets. In or about April 1995, petitioners established
the Bow N Arrow Family Trust and the Naturally Right Co. business
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