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(4) whether petitioners are liable for the section 6662
accuracy-related penalty for 1996, 1997, and 1998.1
Certain additional adjustments, e.g., to itemized deductions, are
computational in nature and will be resolved by our holdings on
the foregoing issues.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. To facilitate disposition
of the above issues, we shall first set forth general findings of
fact and then, where appropriate, make additional findings in
conjunction with our analysis of and opinion on discrete issues.
Petitioners Joseph A. and Sari F. Deihl (individually
referred to as Mr. Deihl and Mrs. Deihl, respectively) are
husband and wife. During the years in issue and at the time the
petitions were filed in these cases, petitioners resided at 4627
East Foothill Drive, Paradise Valley, Arizona 85253. Petitioners
have two children, Joseph Deihl II (Joe II) and William Deihl
(Bill). During the years in issue, Joe II was married to Kim,
and Bill was married to Denyse. Petitioners also have several
grandchildren.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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