Darold D. Friesen and Rosella M. Friesen - Page 2

               Petitioners resided in Henderson, Nebraska, at the time that           
          their petition was filed with the Court.                                    
          Respondent's Notices of Deficiency                                          
               By notices dated May 12, 1995, respondent determined                   
          deficiencies in petitioners' Federal income taxes for the taxable           
          years 1990 and 1992, as well as additions to tax, as follows:               

          Darold D. Friesen                                                           
          Addition to tax                                                             
          Year     Deficiency       Sec. 6651(a)(1)                                   
          1992     $1,391           $185.75                                           
          Rosella M. Friesen                                                          
          Addition to tax                                                             
          Year     Deficiency       Sec. 6651(a)(1)                                   
          1990     $709             $177.25                                           

               The deficiency in income tax determined against petitioner             
          Darold D. Friesen is based on respondent's determination that               
          said petitioner failed to report wages in the amount of $14,564             
          received during 1992 from Bosselman, Inc.  The addition to tax              
          under section 6651(a)(1) is based on respondent's determination             
          that petitioner failed to file a timely income tax return for the           
          taxable year 1992.                                                          
               The deficiency in income tax determined against petitioner             
          Rosella M. Friesen is based on respondent's determination that              
          said petitioner failed to report self-employment tax on non-                
          employee compensation in the amount of $5,018 received during               


          1(...continued)                                                             



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