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Petitioners' response to the show cause order failed to address
any matter contained in the proposed stipulations. Consequently,
the show cause order was made absolute, and the matters set forth
in respondent's proposed stipulation of facts, together with the
exhibits attached thereto, were deemed stipulated for purposes of
these cases pursuant to Rule 91(f)(3). The matters deemed
stipulated may be summarized as follows.
Petitioners are currently married and were so during the
years at issue. They resided in Kingwood, Texas, at the time
their petitions were filed. Mrs. Stafford filed Federal income
tax returns for 1989, 1990, and 1993, electing married filing
separate status, and reporting the previously noted wage income
earned in her individual capacity. However, she failed to report
her share of community property income on these tax returns.
Mrs. Stafford did not file Federal income tax returns for 1991
and 1992, and her failure to do so for these 2 years was not due
to reasonable cause.
Mr. Stafford did not file Federal income tax returns for
1989, 1990, 1991, 1992, and 1993, and his failure to do so for
all years was not due to reasonable cause. Mr. Stafford received
an IRA distribution in 1990 which was an early distribution to
which a 10-percent penalty applies. The additions to tax
pursuant to section 6654 are due from Mr. Stafford for 1989 and
1990 because he underpaid his estimated tax for both years.
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