- 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