- 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. businessPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011