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The Court agrees with and adopts the opinion of the Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: Respondent determined the
following deficiencies in petitioner's Federal income taxes and
additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1993 $14,872 $2,138.25 $328.95
1994 16,526 2,131.50 396.28
1995 12,731 3,099.25 670.20
After concessions by the parties, the issues for decision
are: (1) Whether petitioner is entitled to refunds of any
overpayments made for the 1993, 1994, and 1995 tax years; (2)
whether petitioner is liable for an addition to tax pursuant to
section 6651(a)(1) for 1995; and (3) whether petitioner is liable
for an addition to tax pursuant to section 6654(a) for 1995.
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 the petition
was filed, petitioner resided in Elkhart, Indiana. During the
years in issue, petitioner was married to James Williams (Mr.
Williams).
In February 1997, petitioner was informed by the Internal
Revenue Service (IRS) that it had no record of petitioner's
filing her 1993, 1994, and 1995 Federal income tax returns.
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