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the full amount of the foreign earned income exclusion for 1999;
(5) whether petitioner is liable for additions to tax under
section 6651(a)(1) for 1998 and 1999; (6) whether petitioner is
liable for civil fraud penalties under section 6663(a), or in the
alternative, accuracy-related penalties under section 6662(a) for
1998, 1999, 2000, 2001, and 2002; (7) whether petitioner Annette
Talmage is liable for the accuracy-related penalty under section
6662(a) for 2002; and (8) whether the assessment of deficiencies
for 1999 and 2000 is barred under section 6501(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Corbett, Oregon, when their petition was filed.
A. Background
Petitioner was born and raised in Utah. After he graduated
from high school in 1971, petitioner enrolled at Brigham Young
University (BYU) in Provo, Utah. In 1972, petitioner left BYU to
serve a 2-year mission in Japan for the Church of Jesus Christ of
Latter-Day Saints. While on his mission, petitioner met Kumiko
Wako and returned with her to Salt Lake City, Utah, where they
married on August 12, 1975. Petitioner re-enrolled at BYU and
graduated with a degree in business administration and Asian
studies. In February 1978, petitioner and Kumiko Wako Talmage
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