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whether petitioner is liable for an accuracy-related penalty
under section 6662.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time he filed the
petition, petitioner resided in Walnut, California.
A. Background
During 1996, petitioner worked as the director of
acquisitions for K Young Homes, Inc. From November 1974 to March
1996, Douglas T. Kimm (petitioner’s father), owned a 7-Eleven
franchise and operated other businesses within Southern
California. During the year in issue, petitioner’s father lived
with his daughter and with petitioner in their respective
apartments. Petitioner’s father would travel back and forth
between the two apartments. For more than half of the year 1996,
petitioner’s father resided with petitioner in his apartment.
B. Proposed Business Arrangement
During the last quarter of 1996, petitioner spoke to his
father about helping petitioner locate U.S. real estate
investment opportunities for the purpose of selling interests to
1 All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
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