Carolyn Webb - Page 4

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          under section 6651(a)(1) for 1990, 1991, and 1992 for failure to            
          file returns.  We hold they are.  (4) Whether petitioners are               
          each liable for additions to tax under section 6654 for the                 
          failure to pay estimated tax for 1990, 1991, and 1992.  We hold             
          they are.  (5) Whether a penalty for maintaining a frivolous                
          position should be imposed against each petitioner under section            
          6673.  We hold it should be with respect to petitioner but not as           
          to Carolyn Webb.                                                            
                                  FINDINGS OF FACT                                    
               A few of the facts have been stipulated and are so found.              
          The stipulated facts and the accompanying exhibits are                      
          incorporated into our findings by this reference.  At the time              
          they filed their separate petitions in these cases, petitioners,            
          husband and wife, resided in Vallejo, California.                           
               Petitioners did not file Federal income tax returns for                
          1990, 1991, and 1992, nor did they pay any taxes during those               
          years, except for $20 in withholdings from Carolyn Webb's 1992              
          wage income as shown on Form W-2.  To determine the income that             
          petitioner received for the taxable years in issue, respondent              
          prepared substitute income tax returns for those years.  For 1990           
          and 1991, respondent used Information Returns Processing (IRP)              
          transcripts.  The IRP transcripts are based upon information                
          submitted to the Internal Revenue Service (IRS) by payors who               
          filed information returns with the IRS showing that they paid               
          certain amounts to petitioner during 1990 and 1991 for the                  



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