- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011