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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
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