- 3 - (3) Whether petitioners are liable for an addition to tax under section 6651(a)(1) for failure to timely file an income tax return. We hold that they are. Background Some of the facts have been stipulated, and they are so found. Petitioners resided in Southfield, Michigan, at the time that their petition was filed with the Court. A. Petitioners During 1997, the taxable year in issue, petitioner Robert Lee Waters (petitioner) was employed full-time as a teacher by the Board of Education of Detroit, Michigan. During that same year, petitioner Rebecca Waters was a housewife. B. Acquisition of the Hazelwood Property In June 1986, a group of six individuals (the land contract vendees) purchased a parcel of improved real estate in Detroit, Michigan (the Hazelwood property), under a land contract. The land contract vendees included petitioners, petitioner’s father, Marland and Dortha Moore, and Marland Moore’s mother. The Hazelwood property consisted of a 38-unit, 4-story apartment building with an elevator. The memorandum of land contract that was recorded with the Register of Deeds for Wayne County, Michigan, did not disclose the purchase price of the Hazelwood property.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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