2 At the time the petition was filed, petitioners resided in Beloit, Wisconsin. With respect to petitioner David J. Fogderud (Mr. Fogderud), respondent determined deficiencies and additions to tax as follows: Additions to Tax Year Deficiency Sec. 6651(a) Sec. 6654(a) 1994 $1,624 $406 $84.28 1995 1,796 449 97.34 With respect to petitioner Patricia A. Fogderud, respondent determined deficiencies and additions to tax as follows: Additions to Tax Year Deficiency Sec. 6651(a) Sec. 6654(a) 1994 $1,624 $406 $84.28 1995 1,796 449 97.34 Petitioners filed an Objection to respondent's motion to dismiss, a Supplemental Objection, a Second Supplemental Objection, and respondent filed a Response to Petitioners' Objection, as Supplemented, to respondent's motion. A hearing was held on respondent's motion. During the Court's conference call with the parties, Mr. Fogderud decided not to appear at the hearing. The parties filed a stipulation of facts. The stipulated facts are as follows. The separate notices of deficiency for the taxable years 1994 and 1995 upon which this case is based were mailed from Milwaukee, Wisconsin, 53203, to each petitioner at the same last known address in Beloit, Wisconsin, 53512, by certified mail on December 2, 1997. A certified piece of first class mail, mailed from Milwaukee,Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011