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tax for each of the years 1998 and 1999 that is not due to fraud.
We hold that they are to the extent discussed below.
6. Whether petitioners are liable for additions to tax
under section 6651(a)(1) and (2) for failure to timely file their
1998 income tax return and to pay the tax shown as due on that
return. We hold that they are in the amounts of $3,277.35 and
$2,549.05, respectively.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners lived in Newport Beach, California, when they
filed their petition. Petitioner is an attorney and has
practiced law in California since 1969. Mrs. Graham was a travel
agent during the years in issue.
Petitioners have owned a cabin in Big Bear, California,
since the early 1970s. During the years in issue, petitioner had
three personal bank accounts, one of which was at Security First
Bank in Big Bear (the Big Bear account).
Donald Lewellen (Lewellen), a certified public accountant,
prepared petitioners' income tax returns for tax years 1972
through 1998. He prepared their amended 1998 return in November
1999.
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