Evelyn N. Williams - Page 2




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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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