- 3 - 2. Whether $149,200 seized from petitioners’ home on March 19, 1998, is petitioners’ taxable income from a fencing operation for 1997. We hold that petitioner Larry Dean Sykes had a nontaxable cash hoard of $40,000 on December 31, 1996, and that $109,200 of the $149,200 is taxable income for 1997. 3. Whether petitioners are liable for the accuracy-related penalty imposed by section 6662(a) for 1997. We hold that they are. References to petitioner are to Larry Dean Sykes. References to Mrs. Sykes are to petitioner Ruby Sykes. Section references are to the Internal Revenue Code in effect during the year in issue, and Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioners Petitioners are married and lived in Ozark County, Missouri, when they filed the petition in this case. Petitioner’s father abandoned his family when petitioner was young. Petitioner’s mother was disabled. His maternal grandparents raised him and his older brother Danney. Petitioner’s grandfather died in 1970. Petitioners were married in 1977. Mrs. Sykes had a 1-year- old son, Gary, when petitioners married. Petitioner raised GaryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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