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6651(a)(1) for 1994 and 1995;1 and (6) whether petitioners are
liable for an addition to tax for failing to make estimated
Federal income tax payments pursuant to section 6654 for 1995.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, supplemental stipulation of facts, and
attached exhibits are incorporated herein by this reference. At
the time they filed their petition, petitioners resided in
Tulare, California.
Petitioners filed their 1994 Federal income tax return
(return) on September 11, 1995. Petitioners did not file a
return for 1995.
Payments from Conoco
Prior to and during the years in issue, petitioner Pieter
Dykstra (Mr. Dykstra) held an interest in an oil lease from
Conoco. During this time, Mr. Dykstra was obligated to pay
monthly working costs to Lauck and Associates (Lauck), the
operator of the well. When Mr. Dykstra failed to make such
payments, Lauck obtained a mechanic's lien against Mr. Dykstra's
interest and notified Conoco that all future royalty payments
should be made to Lauck.
1 For 1995, respondent asserted an addition to tax pursuant
to sec. 6651(a)(1) against Mrs. Dykstra in the alternative to an
addition to tax pursuant to sec. 6651(f).
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