- 3 -
(2) whether Hillside Dairy is liable for the accuracy-
related penalty under section 6662(a) for the taxable years ended
November 30, 1995, 1996, and 1997.
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.
When the petitions were filed in these cases, the residence
of the Schmidts, as well as the principal place of business of
Hillside Dairy, was in Parker, South Dakota.
A. The Schmidts
The Schmidts are husband and wife; they have two children.
In March 1981, the Schmidts entered into a contract for deed to
acquire 20 acres (the homestead).2 The homestead includes a
house (the farmhouse), where the Schmidts have resided since
1981. Between February 1985 and January 1986, the Schmidts
acquired 140 additional acres adjoining the homestead. The
homestead and the 140 acres are referred to collectively as the
Schmidt farm. The Schmidt farm consists of pasture, farmland,
and cow lots. A dairy barn, machine sheds, grain bins, and feed
grain bulk bins, as well as the farmhouse, are located on the
Schmidt farm.
2The homestead was Mr. Schmidt’s childhood home where he
lived with his parents until he married Mrs. Schmidt in 1974.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011