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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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