- 3 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011