Hugh Wilkinson and Evelyn Wilkinson - Page 3

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          Respondent also determined in the alternative that petitioners               
          are liable for additions to their 1988 through 1990 taxes under              
          sections 6651(a)(1) and 6654.                                                
               Respondent conceded in the answer that petitioners are not              
          liable for the addition to tax under section 6661 or the                     
          penalties under section 6662.  Following this concession, and a              
          ruling by the Court as to 1990, the only issues left to decide               
          are:                                                                         
               1.   Whether the period of limitations for assessment of tax            
          for 1988 and 1989 expired before respondent issued the notice of             
          deficiency to petitioners.  We hold it did not.                              
               2.   Whether petitioners are liable for the deficiency                  
          determined by respondent in petitioners' 1989 income tax due to              
          unreported income.  We hold they are.                                        
               3.   Whether petitioners are liable for the addition to tax             
          for fraud under section 6653(b)(1) for 1988 and the addition to              
          tax for fraudulent failure to file under section 6651(f) for                 
          1989.  We hold they are not.                                                 
               4.   Whether petitioners are liable for additions to tax for            
          failing to timely file their 1988 and 1989 returns under section             
          6651(a).  We hold they are.                                                  
               5.   Whether petitioners are liable for additions to tax for            
          failing to pay estimated taxes under section 6654 for 1988 and               
          1989.  We hold they are.                                                     






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