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All section references are to the Internal Revenue Code in effect
for the years in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
The issues for decision are: (1) Whether petitioner is
liable for the deficiencies determined by respondent, (2) whether
petitioner is liable for additions to tax for failing to file a
Federal income tax return for 1994 and 1995, (3) whether
petitioner is liable for additions to tax for failing to make
estimated Federal income tax payments for 1994 and 1995, and (4)
whether petitioner engaged in behavior warranting the imposition
of a penalty pursuant to section 6673(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time she filed her
petition, Timie A. Morin (Ms. Morin) resided in Yakima,
Washington.
During 1994 and 1995, Ms. Morin worked as a bookkeeper. In
1994 and 1995, Ms. Morin earned $29,410 and $27,716,
respectively, from Les Morin Subaru as compensation for her
services as a bookkeeper. Ms. Morin did not file Federal income
tax returns for 1994 and 1995.
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Last modified: May 25, 2011