Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia & Carol Ann Gorveia, a.k.a. Carol Gouveia, et al. - Page 4

                                        - 4 -                                         
               (6) whether petitioners are liable for the accuracy-related            
          penalty for negligence or disregard of rules or regulations                 
          pursuant to section 6662(a) for each of the years at issue.                 
                                  FINDINGS OF FACT                                    
          I.   Background                                                             
               Some of the facts have been stipulated.  We incorporate the            
          stipulated facts into our findings by this reference.  When the             
          petitions in these cases were filed, the Gouveias4 resided in               
          Pismo Beach, California.  Although the Pago and the McKenzie                
          Trusts’ petitions alleged that the trusts maintained their                  
          principal places of business in California, the parties did not             
          stipulate or otherwise introduce any evidence regarding the                 
          addresses of the trustees of the trusts as of the date the                  
          petitions were filed.                                                       
               A.   The Gouveias’ Automobile Restoration Business                     
               In 1976, petitioner started an automobile restoration                  
          business in his father’s garage.  Petitioner had previously                 
          studied welding, auto body, and machine tool theory at a junior             
          college.  In 1977, his cousin became a partner in the business,             
          but in 1978, petitioner purchased his cousin’s interest and                 
          continued the business under the name of “Brassworks”.  In the              


               4Only Mr. Gouveia appeared and testified at trial.  However,           
          counsel for petitioners represented that Mrs. Gouveia, who is               
          also a petitioner, was aware of these proceedings, had authorized           
          Mr. Gouveia and his counsel to represent her interests, and has             
          agreed to be bound by the results of this litigation.                       




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