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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.
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