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(5) Are petitioners liable for each of the years at issue
for the addition to tax under section 6651(a)(1)? We hold that
they are.
FINDINGS OF FACT3
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioners resided in
Indianapolis, Indiana (Indianapolis). Petitioner Tommy Owens,
Jr. (Mr. Owens) and petitioner Dawn R. Owens (Ms. Owens) had
moved to Indianapolis from Toledo, Ohio (Toledo), in 1988 and
1990, respectively.
From January through April 1993, petitioners resided in a
mobile home and paid lot rent to Happy Hollow Trailer Lodge.
During that period, their monthly lot rent was $150. During
1993, petitioners paid rent and fees in connection with their
mobile home totaling $505 and also paid for their telephone,
cable, and electricity usage at that mobile home.
Starting in May 1993, petitioners rented a house on Walker
Street in Indianapolis (Walker Street property) in which they
lived until May 1994. Petitioners made monthly rent payments of
$400 for the Walker Street property to Holly Paul. During 1993,
petitioners paid at least $2,420 of rent and/or fees to Holly
Paul, and during 1994 they paid at least $1,000 of rent to Holly
3Although not expressly stated, our Findings of Fact and
Opinion pertain to the years at issue unless otherwise indicated
or expressly stated for clarity.
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