Thomas and Janice Gleason - Page 3

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               (3) Whether petitioners are liable for the section 6662                
          accuracy-related penalty for 1994 and 1995.1                                
          Certain additional adjustments, e.g., to itemized deductions and            
          exemption amounts, 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 and the S Corporations                                          
               Petitioners Thomas and Janice Gleason (individually referred           
          to as Mr. Gleason and Mrs. Gleason, respectively) are husband and           
          wife.  On the petition filed in this case, petitioners stated               
          that their mailing address was in Kentwood, Michigan, and their             
          legal residence was in Long Beach, Mississippi.                             
               The principal issues in this case revolve around                       
          Mr. Gleason’s involvement with various S corporations.2  In 1987,           

               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.            
               2 Mrs. Gleason would appear to have had little involvement             
          with the S corporations, and the record does not clarify the                
                                                             (continued...)           





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