- 3 - 5. Whether petitioners, pursuant to section 6654(a), are liable for additions to tax for failure to make estimated tax payments. We hold that they are liable to the extent provided below. 6. Whether petitioners have asserted frivolous and groundless arguments that warrant the imposition of a penalty pursuant to section 6673. We hold that a penalty is not warranted. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time their joint petition was filed, petitioners' mailing address was in Kernersville, North Carolina. During the years in issue, Albert Cujas was married to Susan Cujas and was self-employed as a physical therapist. Petitioners filed a joint Federal income tax return for 1991, but did not file returns for 1992 or 1993. The Internal Revenue Service audited petitioners' 1991 return, and Agent Jerry Gardner was assigned to the case. He notified petitioners in writing that their 1991 return was being audited. In this correspondence, he asked petitioners to meet with him and to provide records relating to their 1991 income and expenses. Petitioners did not comply with Agent Gardner's requests. After Agent Gardner had completed his audit of petitioners' 1991 return, he began an audit relating to petitioners' 1992 andPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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