- 2 - 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.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011