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feed for each of the years in issue; (b) a 1990 trip to Belgium;
and (c) depreciation for a barn for each of the years in issue; and
(3) whether petitioner is liable for the section 6651(f) fraudulent
failure to file addition to tax, or in the alternative the section
6651(a)(1) failure to file addition to tax, for each of the years
in issue.1
All section references are to the Internal Revenue Code as in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedures. Some of the facts have
been stipulated, and the stipulated facts are incorporated in our
findings by this reference.
General Findings
At the time the petition was filed, petitioner resided in
Tennessee. During the years in issue, petitioner was married to
Juanita Johnson; she resided much of the time in Panama City,
Florida. Petitioner did not file Federal income tax returns for
any of the years in issue.
For convenience and clarity, we have combined our remaining
findings of fact and opinion with respect to each issue.
1 Petitioner concedes that should we conclude that the
sec. 6651(f) addition to tax is not applicable, then the sec.
6651(a)(1) addition to tax would be applicable to any finally
determined deficiency.
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