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MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: Respondent determined a Federal income tax
deficiency for petitioners’ 1995 taxable year in the amount of
$64,745. Respondent also determined an addition to tax of
$16,295 pursuant to section 6651(a)(1) and an accuracy-related
penalty of $12,949 under section 6662(a). After concessions, the
sole issue for decision is the claim by Tony D. Ishizaki
(petitioner) for relief from joint and several liability for the
deficiency, addition, and penalty determined by respondent.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code of 1986, as amended, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
At the time of filing his petition in this case, petitioner
provided an address in Montebello, California. Petitioner’s
educational background consists of a high school education that
continued partially through the tenth grade and approximately 3
months of junior college courses. Thereafter and throughout all
relevant periods, petitioner has been involved in business
ventures relating to the manufacture and sale of furniture.
Prior to his marriage, petitioner created a company called Tony
Ishizaki Studios which operated in this sector. Then, in 1986
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