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Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions,1 the issues for decision are: (1)
Whether petitioners are liable for the deficiencies determined by
respondent, (2) whether petitioners are liable for additions to
tax for failing to file a Federal income tax return for 1995, and
(3) whether petitioners engaged in behavior warranting the
imposition of a penalty pursuant to section 6673(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
their petition, Kenneth G. Bohnet (Mr. Bohnet) and Kim M. Bohnet
(Mrs. Bohnet), husband and wife, resided in Ephrata, Washington.
In 1995, Mr. Bohnet earned $65,500 from Korach & Wilson
Insurance, Inc., $855 in nonemployee compensation from Fortis
Investors, and $173 in interest income. In 1995, Mrs. Bohnet
earned $21,874 from Grant County, Washington, and $11 in interest
1 Respondent concedes that the credit for withholding
income tax for Kim M. Bohnet should be $1,976 and not $1,356 as
determined. Petitioners concede that their interest income for
1995 is taxable.
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Last modified: May 25, 2011