- 4 - (15) whether petitioners are liable for accuracy-related penalties under section 6662(a) and (b)(2) for 1989, 1990, and 1993 because of substantial understatements of their income tax. FINDINGS OF FACT3 Some of the facts have been stipulated and are so found. The stipulation of facts filed by the parties is incorporated in this opinion by this reference. Background Petitioners resided in Rapid City, South Dakota, when they filed their petition. Hereinafter, references to petitioner are to Richard Haeder, and references to Mrs. Haeder are to Judith Haeder. For each of the years in issue, petitioners claimed dependency exemptions for two minor children. After completing a clerkship in Washington, D.C., petitioner had started working for a large law firm located in Portland, Oregon, in 1967. During the years at issue, petitioner was an attorney licensed to practice law in the States of Oregon and 3Contrary to Rule 151(e), which governs the form and content of briefs submitted to the Tax Court, petitioners provided in their opening brief a “statement of facts” that was not presented in numbered statements and that, for the most part, did not give references to the pages of the transcript, exhibits, or other sources relied upon to support the statements contained therein. Furthermore, in their reply brief, petitioners did not set forth objections to respondent’s proposed findings of fact. Consequently, in our findings of fact, we have relied heavily upon respondent’s proposed findings. By failing to follow the Court’s Rules, “petitioners have assumed the risk that we have not considered the record in a light of their own illumination.” Monico v. Commissioner, T.C. Memo. 1998-10.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