- 2 - tax; and (3) whether petitioners are liable for an accuracy- related penalty under section 6662(a). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioners resided in Davis, California, at the time they filed their petition in this case. Ralph W. Emerson (petitioner) received an undergraduate degree from the University of California at Los Angeles, studying neurobiology, mathematics, and chemistry. He then attended graduate school at Harvard University, studying informational systems and chemistry. Prior to 1998, petitioner was a research biologist engaged in the business of developing pesticides, fungicides, and other agricultural products. Petitioner has attained about 14 patents from the U.S. Patent Office dealing with chemistries and biologies of biochemical pesticides and about twice that amount in international patents. Petitioner’s Relationship with ProGuard On June 26, 1994, petitioner entered into a contract for services (the contract) with ProGuard, Inc. (ProGuard), to perform scientific research as an independent contractor. Petitioner and ProGuard shared an interest in developing “saferPage: 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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