Wayne E. and Dorothy E. Wells - Page 3

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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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