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The decision to be entered is not reviewable by any other court,
and this opinion should not be cited as authority.
Respondent determined penalties of $12,264, $15,056, and
$30,129 under section 6663(a) for the years 1991, 1992, and 1994,
respectively. In the answer, respondent alleges, in the
alternative, that if petitioner Gail Campana is not liable for
the penalties under section 6663(a) for the years at issue, she
is liable for the accuracy-related penalties under section
6662(a), as increases of deficiency under section 6214(a). The
issues for decision, therefore, are whether part of the
underpayments of tax for the years 1991, 1992, and 1994 is due to
fraud, or in the alternative, whether the underpayments are due
to negligence or intentional disregard of rules or regulations.
Some of the facts have been stipulated and are so found.
The accompanying exhibits are incorporated herein by reference.
Background
Gail Campana (petitioner) resided in Lavallette, New Jersey,
when the petition was filed in this case.
Petitioner and her husband, Paul Campana, operated a driving
school for prospective drivers of noncommercial vehicles. They
sold the school in 1992.
In 1989 petitioner and Mr. Campana,1 became investors in CNC
Trading Company of Marlton, New Jersey (CNC). CNC was owned and
1Paul Campana died on May 13, 1992.
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