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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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