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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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