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This case is before the Court on petitioners' Motion To
Withdraw Deemed Admissions, filed pursuant to Rule 90(f). A
hearing on this motion was held at Oklahoma City, Oklahoma.
By separate notices, respondent determined deficiencies in,
and additions to, petitioners' Federal income taxes as follows:
Wayne E. Wells
Additions to Tax--Sections
Year Deficiency 6651(a)(1) 6653(a)(1)(A)6653(a)(1)(B) 6653(a)6654
1986 $7,245 $1,211 $369 * --- ---
1987 8,466 2,117 423 * --- $456
1988 22,038 5,510 --- --- $1,102 600
1989 9,221 2,305 --- --- --- 623
* Amount equal to 50% of the interest due on the underpayment due to negligence.
Dorothy E. Wells
Additions to Tax--Sections
Year Deficiency 6651(f) 6653(b)(1) 6653(b)(1)(A) 6653(b)(1)(B)6654
1986 $6,053 --- --- $4,540 * $292
1987 5,851 --- --- 4,388 * 317
1988 5,032 --- $3,774 --- --- 322
1989 8,135 $6,101 --- --- --- 551
* Amount equal to 50% of the interest due on the underpayment due to fraud.
The deficiencies and additions to tax for Wayne E. Wells
(Mr. Wells) were based upon respondent's determination that Mr.
Wells negligently failed to report wage income and Schedule C
income for the years in issue, as well as interest income and a
profit sharing distribution in 1988. Similar determinations for
taxable years 1983, 1984, and 1985 were sustained in respondent's
favor in Wells v. Commissioner, T.C. Memo. 1990-58.
The deficiencies and additions to tax for Dorothy E. Wells
(Mrs. Wells) were based upon respondent's determination that Mrs.
Wells failed to report Schedule C income for the years in issue.
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