- 2 -
$66,056.25 for 1998 and the accuracy-related penalty under
section 6662(a) of $37,307.20 for 1997 and $53,845 for 1998.
After concessions,2 the sole issue for decision is whether
petitioners are liable for accuracy-related penalties of $3,354
for 1997 and $27,638 for 1998. We hold that they are.
FINDINGS OF FACT
Some of the facts were stipulated and are so found.
A. Petitioners
Petitioners are married and resided in Corbett, Oregon, when
they filed their petition. Petitioners are high school
graduates. Charlotte Rogers attended 1 year of college.
Charlotte Rogers was employed as a bookkeeper and general
office worker from 1958 to 1961. She worked in sales for United
Airlines from 1961 to 1973. She was a Shaklee distributor from
1973 to 1987, and she owned and operated a restaurant from 1987
to 1992. Dennis Rogers owned Columbia Sheetmetal until February
1993. Beginning around 1965, petitioners began to buy rental
1(...continued)
Internal Revenue Code as amended and in effect for 1997 and 1998.
Rule references are to the Tax Court Rules of Practice and
Procedure.
2 The parties stipulated that petitioners’ trusts were
invalid for tax purposes and that petitioners have deficiencies
in income tax of $16,771 for 1997 and $138,190 for 1998 and are
liable for the addition to tax for late filing under sec.
6651(a)(1) of $2,768 for 1997 and $33,490 for 1998. They further
stipulated that the amounts of the accuracy-related penalty at
issue in this case are $3,354 for 1997 and $27,638 for 1998.
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