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,
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