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Similar determinations for taxable years 1984 and 1985 were
sustained in respondent's favor in Wells v. Commissioner, T.C.
Memo. 1989-150. However, in the instant case, respondent
determined additions to tax against Mrs. Wells for fraud, rather
than negligence, as had been the case for the previous years.
Background
In their petition, petitioners dispute the "entire amount
for each and every year." Petitioners challenge the correctness
of the adjustments to income and additions to tax by alleging the
following "facts" in support of their assignments of error:
5. The facts upon which the petitioner [sic]
relies as a basis of these proceedings are as follows:
(a) That the petitioners are not liable for
penalties/interest as claimed because no
deficiency exists once the true income is
calculated and the business and personal
deductions are subtracted from the true gross
income.
(b) That the petitioners deny that the
amount stated as gross income in notices of
deficiency is accruate [sic].
(c) That the petitioners are entitled to the
normal business deductions associated with
the tax years at issue all of which were not
calculated to determine taxable income.
(d) That the petitioners are entitled to the
personal deductions associated with the tax
years at issue all of which were not
calculated to determine taxable income.
Respondent filed her answer and denied petitioners'
assignments of error. Respondent also alleged further facts in
support of her fraud determination concerning Mrs. Wells.
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