Wayne E. and Dorothy E. Wells - Page 2

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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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