Craig M. and Rebecca Maxwell - Page 2

                                                - 2 -                                                   
            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'                            




Page:  Previous  1  2  3  4  5  Next

Last modified: May 25, 2011