Walter O. Bowen and Susan M. Bowen, et al. - Page 3




                                        - 3 -                                         
               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           






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

Last modified: May 25, 2011