Patricia B. Paterson, et al. - Page 2




                                         -2-                                          
          section 6663 for 1997 and 1998 (the years at issue).2                       
               Respondent determined that petitioner Patricia B. Paterson             
          (Mrs. Paterson) was liable for a $53,168 deficiency and a $39,876           
          fraud penalty for 1997.  For 1998, respondent determined that               
          Mrs. Paterson was liable for a $16,402 deficiency and a                     
          $12,301.50 fraud penalty.                                                   
               Respondent determined that petitioner George M. Paterson               
          (Mr. Paterson) was liable for a $125,280 deficiency and a $93,960           
          fraud penalty for 1997.  For 1998, respondent determined that Mr.           
          Paterson was liable for a $88,257 deficiency and a $66,192.75               
          fraud penalty.                                                              
               There are three issues for decision.  The first issue is               
          whether petitioners understated their income in the amounts                 
          respondent determined for the years at issue.  We hold that they            
          did.  The second issue is whether petitioners are liable for the            
          fraud penalties for the years at issue.  We hold that they are.             
          The third issue is whether the limitations period bars respondent           
          from assessing petitioners’ taxes for the years at issue.  We               
          hold that it does not.                                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the accompanying exhibits are                  



               2All section references are to the Internal Revenue Code in            
          effect for the years at issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  





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