-3-
to timely file their 1992 income tax return under section
6651(a)(1)? We hold petitioners are liable for both the penalty
and the addition to tax.
All section references are to the Internal Revenue Code for
the year under consideration. All Rule references are to the Tax
Court Rules of Practice and Procedure. All dollar amounts are
rounded.
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. For convenience, we present a background
section and combine our findings of fact with our opinion under
separate issue headings.
Background
Petitioners, husband and wife, resided in Randallstown,
Maryland, at the time they filed their petition. Gregory A. Maslow
(petitioner) emigrated to the United States from Russia in 1974.
He and Marina met (in 1986) and married (in 1988) in the United
States.
During 1992, the year under consideration, petitioner was a
general agent for several life and health insurance companies. In
addition, during 1992 he started a business (known as East-West
International) which was to engage in the export of goods to
Russia.
Petitioners did not file Federal income tax returns for 1988
through 1992 until they were contacted by one of respondent's
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