- 9 - and provides no basis for denying respondent's motion for summary judgment. 1. The Deficiencies The deemed stipulations in these cases establish that petitioners were married and residents of Texas, a community property State, during the tax years at issue. Thus, on the facts here presented, each petitioner is liable for the tax on his or her respective share of community property income. See Hopkins v. Bacon, 282 U.S. 122 (1930); Poe v. Seaborn, 282 U.S. 101 (1930). Petitioners have not asserted that the notices of deficiency are arbitrary or erroneous and have failed to offer any evidence disputing respondent's determinations as to the deficiencies. Moreover, every item of income that respondent determined was received by each petitioner individually is supported by documentation to which petitioners are deemed to have stipulated, including the Federal income tax returns filed by Mrs. Stafford reporting wage income earned in her individual capacity. Statements in a tax return are admissions. Waring v. Commissioner, 412 F.2d 800, 801 (3d Cir. 1969), affg. per curiam T.C. Memo. 1968-126; Estate of Hall v. Commissioner, 92 T.C. 312, 337-338 (1989); Lare v. Commissioner, 62 T.C. 739, 750 (1974), 3(...continued) was redesignated as the Internal Revenue Code of 1986 by the 99th Congress on Oct. 22, 1986, Pub. L. 99-514, sec. 2(a), 100 Stat. 2095.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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