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FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and
the stipulated exhibits are incorporated herein by this
reference.
Petitioners Edward A. Robinson III (hereinafter sometimes
referred to as Edward), and Diana R. Robinson resided in
Louisiana when they filed their petition in the instant case.
A. Edward’s Background
In 1970, Edward was graduated from Grambling State
University, cum laude, with a double major in political science
and English. In 1971, Edward received a master’s degree in
criminal jurisprudence from the State University of New York at
Albany. In 1975, Edward received his law degree from Rutgers
University. Edward also was awarded an honorary LL.D. from World
University, in Tucson, Arizona.
After his Rutgers graduation, Edward worked as the chief
administrator of the Louisiana Justice Department. Edward
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“other interest” that was reported on the Schedule C (Profit or
Loss From Business) attached to their 1995 tax return. The
$69,617 interest payment was made in respect of petitioners’
underpayment of their 1987 Federal individual income tax
liability. The other adjustments that respondent made to
petitioners’ 1995 return were to petitioners’ Schedule A
(Itemized Deductions) and to the computation of the self-
employment tax deduction and the self-employment tax liability
for Edward A. Robinson III. These adjustments are computational;
their resolution depends on our determination of the issue for
decision.
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