Tashina Baker - Page 3

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                  The deficiencies in income taxes are based on respondent's                            
            determination that petitioners failed to report income on timely                            
            filed income tax returns for the taxable years in issue.  Because                           
            petitioners were married and domiciled in Texas, a community                                
            property state, respondent allocated one-half of the total income                           
            for each year, as reconstructed by respondent, to each                                      
            petitioner.  Respondent also determined that all of the total                               
            income for each year, except for $900 in 1991 and $1,450 in 1992,                           
            is attributable to petitioner Robert R. Baker for self-employment                           
            tax purposes.  See sec. 1402(a)(5)(A); see also sec. 164(f).  It                            
            is this latter determination that explains the difference between                           
            petitioners regarding the amount of the deficiencies determined                             
            by respondent.                                                                              
                  The additions to tax under section 6651(a)(1) are based on                            
            respondent's determination that petitioners' failure to file                                
            timely income tax returns for the years in issue was not due to                             
            reasonable cause.  The additions to tax under section 6654(a) are                           
            based on respondent's determination that petitioners failed to                              
            pay the requisite estimated income taxes.                                                   
            Petitioner Tashina Baker's Petition and Amended Petition2                                   

            2 The petition filed at docket No. 5931-95 by petitioner                                    
            Tashina Baker and the petition filed at docket No. 5932-95 by                               
            petitioner Robert R. Baker are virtually identical.  Similarly,                             
            the history of docket No. 5931-95 subsequent to the filing of the                           
            petitions parallels exactly the history of docket No. 5932-95.                              
            Accordingly, we shall limit our discussion in this Opinion to the                           
            petition filed at docket No. 5931-95.  It should be understood,                             
                                                                          (continued...)                




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