- 3 -
they are not.
(5) Are petitioners liable for each year at issue for the
excise tax under section 4973(a) for excess IRA contributions?
We hold that Ms. Whitehead is.
(6) Are petitioners liable for each year at issue for the
accuracy-related penalty under section 6662(a)? We hold that
they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found
except as stated herein.
Petitioners, who at all relevant times were husband and
wife, resided in Sumner, Washington, at the time the petition was
filed.
Petitioners have three children, who were born in April
1993, June 1996, and July 2000, respectively.
Burien Nissan
At all relevant times, Burien Nissan, a corporation orga-
nized in the State of Washington, operated an automobile dealer-
ship located in Burien, Washington. At least during the years at
issue, Mr. Whitehead was president of Burien Nissan. During each
year at issue, Burien Nissan had current earnings and profits of
at least $24,000.
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