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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 and
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