- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011