-3-
By amendment to answer, respondent asserts in the
alternative that, if petitioner Robert E. Iles is not liable for
part or all of the additions to tax for fraud for any of the
years in issue, then he is liable for additions to tax under
sections 6653(a) (negligence) and 6651(a) (failure to timely file
tax returns) for those years.
On April 14, 1988, after respondent issued the notices of
deficiency and a joint petition was filed as to all 3 years,
petitioners Robert E. Iles, hereinafter sometimes referred to as
Robert, and Monica M. Iles, hereinafter sometimes referred to as
Monica, filed joint tax returns for 1981 and 1982. See Phillips
v. Commissioner, 86 T.C. 433 (1986), affd. on this issue and
revd. on another issue 851 F.2d 1492, 1496-1498 (D.C. Cir. 1988),
discussing the effect of filing joint tax returns under such
circumstances. In the above-noted amendment to answer,
respondent recomputed the deficiencies for 1981 and 1982 by
combining the adjustments to income determined in the separate
notices of deficiency and using joint filing rates. Respondent’s
recomputation also reflects respondent’s position regarding
income reported and deductions claimed on petitioners’ late-filed
tax returns, makes certain concessions, and increases some income
items. See sec. 6214(a). The results of respondent’s
recomputation are as follows:
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