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affd. without published opinion 521 F.2d 1399 (3d Cir. 1975)
("Statements made in a tax return signed by a taxpayer may be
treated as admissions."); Sirrine Bldg. No. 1 v. Commissioner,
T.C. Memo. 1995-185 ("As statements of a party opponent, the
returns are admissions under rule 801(d)(2) of the Federal Rules
of Evidence."); Estate of Ford v. Commissioner, T.C. Memo. 1993-
580, affd. 53 F.3d 924 (8th Cir. 1995); Estate of Kreis v.
Commissioner, T.C. Memo. 1954-139, affd. 227 F.2d 753 (6th Cir.
1955). Hence, Mrs. Stafford has admitted receiving wage income
in her individual capacity in the amounts as determined in the
notice of deficiency.
Mrs. Stafford is deemed to have stipulated that she failed
to report her share of community property income on her 1989,
1990, and 1993 Federal income tax returns and that she filed no
income tax returns in 1991 and 1992. Mr. Stafford is deemed to
have stipulated that he failed to file Federal income tax returns
for all years at issue. Consequently, the records in these cases
amply support respondent's determinations of the amounts of
income that petitioners received in their individual capacities,
the years of receipt, and petitioners' liabilities for their
respective shares of community property income.
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