Edward W. and Edith M. Arnold - Page 2




                                         -2-                                          
         Unless otherwise indicated, all section references are to the                
         Internal Revenue Code in effect for the years in issue, and all              
         Rule references are to the Tax Court Rules of Practice and                   
         Procedure.                                                                   
              After a concession by respondent,1 the issues for decision              
         are:  (1) Whether petitioners substantiated deductions, losses,              
         and/or cost of goods sold in excess of amounts respondent allowed            
         or conceded for 2002 and 2003, (2) whether petitioners are liable            
         for self-employment tax in 2002 and 2003, (3) whether petitioners            
         are liable for the section 6651(a)(1) addition to tax for 2003,              
         and (4) whether petitioners are liable for the section 6662(a)               
         penalty for 2002 and 2003.                                                   
                                  FINDINGS OF FACT                                    
              None of the facts have been stipulated.  Confronted with                
         petitioners’ refusal to work toward a stipulation of facts,                  
         respondent filed, among other things, requests for admission                 
         pursuant to Rule 90.  After the Court granted a motion by                    
         petitioners to extend the time for their reply to respondent’s               
         requests for admission, petitioners did not file a response                  
         within the time permitted to respondent’s requests for admission,            
         including the extension of time granted by the Court.                        



               1  Respondent concedes that petitioners substantiated                  
          $3,122.52 in labor expenses for 2003 (attributable to services              
          performed by William Ray).                                                  





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next 

Last modified: November 10, 2007