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indicated. References to petitioners include both Mr. and Mrs.
Bodwell.1
After concessions,2 the issues for decision are: (1)
Whether petitioners had unreported income from painting services
for the taxable years 1989 through 1994. We hold they did. (2)
Whether petitioner incurred self-employment tax for the taxable
years 1989 through 1994. We hold he did. (3) Whether
petitioners are liable for additions to tax under section 6651(a)
for failure to timely file their tax returns for the taxable
years 1989 through 1994. We hold they are liable. (4) Whether
petitioners are liable for additions to tax under section 6654
for failure to pay estimated tax for the taxable years 1989
through 1994. We hold they are liable.
1Mrs. Bodwell died on October 25, 1994. On Feb. 22, 1996,
we ordered that Mr. Bodwell, "the surviving spouse of Betty
Bodwell, Deceased, is appointed special administrator of the
estate of Betty Bodwell, solely for the purpose of maintaining
the present proceeding as to the estate of Betty Bodwell,
Deceased."
2This case originally involved determined deficiencies in
income tax for the years 1982 to 1994, inclusive, totaling
$412,290 and additions to the tax under Secs. 6651(a) and 6654
totaling $102,577.40 and $24,064.18, respectively. By order
dated Mar. 4, 1998, we concluded that respondent’s determinations
of income set forth in the notices of deficiency were arbitrary,
and shifted the burden of proof as to income to respondent. At
trial, respondent presented evidence as to petitioners’ income
only for the years 1989 through 1994. Respondent provided no
arguments on brief that petitioner is liable for tax for the
years 1982 through 1988. Accordingly, we treat the issue of
petitioners’ liability for tax from 1982 through 1988 as conceded
by respondent.
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