- 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