David J. and Patricia A. Fogderud - Page 2




                                          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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