Michael T. Chappell - Page 3




                                        - 3 -                                         
               6.   Whether petitioner is liable for the addition to tax              
          for failure to timely file under section 6651(a)(1) for 1994.  We           
          hold that he is.                                                            
               7.   Whether petitioner is liable for the accuracy-related             
          penalty under section 6662(a) for 1994 and 1995.  We hold that he           
          is.2                                                                        
               Unless otherwise indicated, section references are to the              
          Internal Revenue Code.  Rule references are to the Tax Court                
          Rules of Practice and Procedure.                                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          A.   Petitioner                                                             
               Michael T. Chappell (petitioner) lived in Montgomery,                  
          Alabama, when he filed the petition in this case.                           
               Petitioner and Angela Denise McGraw Chappell (Mrs. Chappell)           
          have been married since 1978.  They have three children.  Lesley            
          Nicole (Nicole) Chappell was born November 22, 1977; Ashley                 
          Brooke (Brooke) Chappell was born April 5, 1982; and Michael                
          Tyrone (Tye) Chappell was born January 12, 1986.  Nicole was                
          diagnosed with Hodgkins disease around July 1995.  Petitioner and           
          Mrs. Chappell lived apart in 1994 and 1995.                                 


               2  Petitioner’s liability for self-employment tax, the self-           
          employment tax deduction, the amount of petitioner’s standard               
          deduction, and whether petitioner’s dependency exemption in 1994            
          is limited by sec. 151(d)(3) are computational.                             





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011