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whether petitioners are liable for the additional interest
imposed by section 6621(c) for the years 1983, 1984, and 1985.
Due no doubt in part to petitioners' departure and
continuous absence from the United States since before the
petition was filed in this case, the parties were unable to agree
upon a stipulation of facts. See Rule 91. Petitioners did not
appear at trial, nor did anyone appear on their behalf. The
evidence consists of videotapes produced in connection with a
videotaped deposition conducted pursuant to Rule 81(j); the
transcript prepared from those tapes; certain exhibits proffered
during the deposition; the testimony of an expert witness called
by respondent; and exhibits introduced based upon admission
requests served upon petitioners by respondent. At the time the
petition was filed, petitioners resided in Poecking, Germany
(then West Germany).
FINDINGS OF FACT
General Background
Petitioners were married in 1982. They filed joint Federal
income tax returns for the years 1983, 1984, and 1985. Hans
Hammann filed returns for the years 1980 and 1981 as a single
individual. Hans Hammann is a German citizen and Cheryl Hammann
is a Canadian citizen. During the years 1983, 1984, and 1985,
Hans Hammann was employed as a union executive in the San
Francisco metropolitan area. He reported earnings from that
employment for those years as follows:
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