- 4 -
reduced on account of any increase in their adjusted gross
income;2 and whether the Careys are subject to an accuracy-
related penalty under section 6662.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The
stipulation of facts filed by the parties, along with
accompanying exhibits, is incorporated herein by this reference.
Residence; Principal Place of Business
On the date the trust filed its petition in this case, its
principal place of business was in Redding, California. On the
date the Careys filed their petition in this case, their
residence was in Bella Vista, California.
Michael Carey
Michael is a licensed occupational therapist. During 1995,
Michael was the proprietor of two residential care facilities for
developmentally disabled adults. Those two facilities were
called Sunshine Residential Program (Sunshine) and Rancho
Residential Program (Rancho). In addition, during at least the
first 11 months of 1995, Michael was obligated by contract to
provide his services as a licensed occupational therapist to the
trust. That contract required Michael to provide various
services to the trust as needed, at $35 an hour. By check dated
2 This also is a computational matter, and, for the same
reasons set forth supra note 1, we shall not further discuss it.
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