Cathy Miller Hardy - Page 3

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               (1)  Does petitioner have unreported income for 1983, 1984,            
          and 1985?  We hold that she does.                                           
               (2)  Is petitioner liable for 1983, 1984, and 1985 for the             
          addition to tax for failure to file a return under section                  
          6651(a)(1)?  We hold that she is.                                           
               (3)  Is petitioner liable for 1983, 1984, and 1985 for the             
          addition to tax for failure to pay estimated tax under section              
          6654(a)?  We hold that she is.                                              
                                  FINDINGS OF FACT5                                   
               Some of the facts have been stipulated and are so found.               
               Petitioner resided in Golconda, Nevada, at the time the                
          petition was filed.                                                         
               Petitioner did not file a Federal income tax return (return)           
          for the years at issue, nor did she at anytime make an attempt to           
          determine whether she was required to file a return for any of              
          those years.                                                                
               Petitioner, who is part German and part Native American and            
          who was raised in the Shoshone Indian culture, has a high school            
          education.  She has been married to Ray Hardy (Mr. Hardy) since             

          4(...continued)                                                             
          885 (1979).  Here, respondent had no opportunity to argue, let              
          alone present evidence, relating to petitioner's claim that she             
          is entitled to a dependency exemption for each of the years at              
          issue.  Accordingly, we shall not consider that claim.  We note             
          that even if we were to consider that claim, the record does not            
          contain any evidence to support it.                                         
          5  Unless otherwise indicated, all of the facts that we have                
          found pertain to the years 1983, 1984, and 1985 (years at issue).           




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