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Craig M. Maxwell
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654
1990 $280,484 $42,621 $18,422
1991 2,571 643 149
1992 68,868 17,205 3,003
1993 70,431 17,153 2,869
Rebecca Maxwell
Additions to Tax
Sec. Sec.
Year Deficiency 6651(a)(1) 6654
1990 $137,827 $34,457 $9,074
1991 904 226 54
1992 32,725 8,181 1,427
1993 29,976 7,494 1,255
Following respondent's concessions we must decide whether
petitioners are entitled to refunds of overpayments for their
1990, 1992, and 1993 taxable years. We hold they are not.
Section references are to the Internal Revenue Code in effect for
the years in issue. Rule references are to the Tax Court Rules
of Practice and Procedure.
Background
All facts have been stipulated and are so found. The
stipulated facts and the exhibits submitted therewith are
incorporated herein by this reference. Petitioners resided in
Riverside, California, when they petitioned the Court.
Petitioners delinquently filed Federal income tax returns
for each of the subject years. Respondent received petitioners'
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Last modified: May 25, 2011