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Clyde E. Owens and Marie W. Owens
Accuracy-related
Year Deficiency penalty
1989 $33,384 $6,677
1990 41,078 8,216
Janet L. Feltrinelli
Accuracy-related
Year Deficiency penalty
1989 $2,635 $527
1990 8,191 1,638
After concessions we must decide the following issues:
1. Whether respondent violated petitioners' Constitutional
rights in these cases. We hold that respondent did not.
2. Whether petitioners' documentary evidence was properly
excluded because petitioners failed to comply with the Court's
orders to identify in writing and exchange that evidence with
respondent. We hold that it was.
3. Whether respondent's determination of petitioners'
income tax deficiency is correct. We hold that it is, except as
conceded by respondent.
4. Whether petitioners are liable for self-employment tax.
We hold that they are.
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