- 3 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011