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compensation, prizes or awards, and capital gains during the
years 1992 through 1995, no part of which was reported on Federal
income tax returns for those years. The additions to tax under
section 6651(a)(1) are based on respondent's determination that
petitioners' failure to file timely Federal income tax returns
was not due to reasonable cause. The additions to tax under
section 6654(a) are based on respondent's determination that
petitioners failed to pay the required estimated income tax for
the years in issue.
Background
On December 24, 1997, this Court received and filed
petitioners' petition. On February 17, 1998, respondent's Motion
To Dismiss For Failure To State A Claim Upon Which Relief Can Be
Granted was filed under Rule 40, and it was requested therein
that the United States be awarded a penalty under section 6673.
Petitioners filed a notice of objection to the motion on
February 23, 1998.
By Order dated February 20, 1998, this Court directed
petitioners to file an amended petition, stating specific
allegations of error in the notice of deficiency and a separate
statement of facts, on or before March 17, 1998. In addition,
this Court set a hearing on respondent's motion on April 20,
1998. Petitioners filed an amended petition on March 16, 1998,
and a hearing was held in accordance with the Order.
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