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are. (5) Whether for 1995 petitioner is liable for an addition
to tax under section 6654(a). We hold he is.
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference. At the time the petition
in this case was filed, petitioners resided in Seattle,
Washington.
FINDINGS OF FACT
Petitioners are husband and wife. Petitioners filed a joint
1994 Federal income tax return on which they reported no taxable
income, but attached two Forms W-2. The first Form W-2 was
issued to Mrs. Fujita by the City of Seattle and indicated that
she earned employee compensation in the amount of $20,419.93.
The second Form W-2 was issued to petitioner by the Boeing Co.
and indicated that he earned employee compensation in the amount
of $43,012.36. On both of these Forms W-2, petitioners wrote
I did not earn "wages", "salary", or "compensation for
services", as defined by Title 26. I am not an
officer, employee or elected official of the United
States, the District of Columbia, or any agency or
instrumentality of the United States or the District of
Columbia. Further, I earned no United States source
income or effectively connected income from within the
United States as defined in Title 26.
Petitioners did not file a 1995 Federal income tax return.
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