Vernon W. Hartman, Jr. and Virginia M. Hartman - Page 2




                                        - 2 -                                          

                               Penalty and Additions to Tax                            
             Year Deficiency Sec. 6651(a)(1) Sec. 6661(a) Sec. 6662(a)                 
             1986  $14,882     $2,853            $2,442        --                      
             1987    13,971    2,811             2,811         --                      
             1988     3,527    882                  --         --                      
             1989     3,825    956                  --         --                      
             1990    10,182    2,546                --         $2,036                  

             Unless stated otherwise, all section references are to the                
             Internal Revenue Code as in effect for the years in issue,                
             and all Rule references are to the Tax Court Rules of                     
             Practice and Procedure.                                                   
                  The parties have stipulated some of the facts.                       
             The stipulation of facts filed by the parties and the                     
             accompanying exhibits are incorporated herein by this                     
             reference.  Petitioners resided in the Commonwealth of                    
             Pennsylvania at the time they filed the instant petition.                 
                  Petitioners did not file income tax returns for the                  
             years in issue, 1986 through 1990, until 1992.  At the time               
             of trial, petitioners had not filed returns for the years                 
             1993 through and including 1996.                                          
                  Respondent concedes that petitioners are not liable                  
             for a small portion of the above deficiencies determined in               
             the notice of deficiency for 1989 and 1990.  The issue for                
             decision is whether petitioners are liable for the subject                
             tax deficiencies, penalty, and additions to tax, other than               
             the portion of the deficiencies for 1989 and 1990 conceded                





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