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Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2)
1981 $40,352.17 $2,017.61 1
1982 1,118.92 55.95 1
1 50 percent of the interest due on the amount of the
deficiency.
For the years in issue, respondent also determined that
petitioners are liable for increased interest under section
6621(c). Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
After concessions, the issues to be decided are: (1)
Whether the period of limitation on assessment of the deficiency
in and additions to tax for the Joneses' 1981 taxable year
expired prior to the date the notice of deficiency was issued;
and, if it did not, (2) whether petitioner is entitled to relief
under section 6013(e) for the 1981 taxable year.
FINDINGS OF FACT
Some of the facts were stipulated for trial pursuant to Rule
91. The parties' stipulations are incorporated herein by
reference and are found accordingly.
1(...continued)
Raymond E. Jones as Mr. Jones, petitioner and Mr. Jones as the
Joneses, and petitioner and the Estate of Raymond E. Jones,
Dorothy J. Jones, Independent Executrix, as petitioners.
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