Mark N. Wright and Erica Y. Wright - Page 4

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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               
               (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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