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Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654(a)
1996 $2,175,165 $356,574.15 $396,193.50 $21,719.58
The only issue remaining for decision is whether petitioner
is liable for the additions to tax under section 6651(a)(1) and
(2) for 1996. We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner resided in Hartford City, Indiana (Hartford), at
the time the petition was filed.
Petitioner attended Purdue University from which he received
a B.S. degree in agricultural economics in 1967. While enrolled
at Purdue University, petitioner took courses in economics,
business management, and accounting.
After graduating from college, petitioner worked for approx-
imately 7-� years as a salesperson for College Life Insurance
Company (College Life) in Indianapolis, Indiana.
While working for College Life, petitioner acquired and
operated an A&W drive-in restaurant. Around 1975, petitioner
resigned from College Life and worked in the restaurant business
on a full-time basis. He has remained in the restaurant business
to at least the date of the trial in this case.
In 1981, petitioner opened a restaurant in Hartford, known
as Richard’s restaurant, which was part of a chain of restaurants
known by the same name. Shortly thereafter, in 1983, petitioner
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