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(4) whether petitioners are liable for the addition to tax
pursuant to section 6651(a)(1) for their 1999 and 2000 taxable years;
(5) whether Mr. Wright is liable for the civil fraud penalty
pursuant to section 6663 for his 1999, 2000, and 2001 taxable
years;
(6) whether, in the alternative, if Mr. Wright is found not
to be liable for the civil fraud penalty pursuant to section 6663
on any portion of the underpayment for any of the years in issue,
petitioners are liable for the accuracy-related penalty, pursuant
to section 6662, on such portion of the underpayment.
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. At the time this petition
was filed, petitioners resided in Sarasota, Florida.
A. General Background
Petitioners had been married for approximately 35 years as
of the time of trial. Mr. Wright has a bachelor of science
degree in business and a master’s degree in business
administration. Mr. Wright is a certified public accountant and
certified financial planner who worked in those capacities during
1999, 2000, and 2001. Mrs. Wright has a high school education.
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