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We hold he did. (3) Whether petitioners are liable for additions
to tax under section 6651(a) for failure to timely file their
Federal income tax returns for the taxable years 1992, 1993,
1994, and 1995. We hold they are liable. (4) Whether
petitioners are liable for additions to tax under section 6654
for failure to pay estimated tax for the taxable years 1992,
1993, 1994, and 1995. We hold they are liable.
We find the following facts based upon the pleadings of this
case and the deemed admissions contained in respondent's request
for admissions.2
FINDINGS OF FACT
Petitioners resided in Everett, Washington, at the time the
petition was filed in this case. The taxable years in issue are
1992, 1993, 1994, and 1995.
For the taxable year 1991, petitioners filed a tax return
which reflected a Schedule C business named Yoshihara
Landscaping. In each of the years in issue, petitioners
contracted to do business in the State of Washington in the name
of the following entities (or a combination of these entities):
Mountlake College (Mountlake); Yoshihara Landscaping
(Landscaping); and Green Acres Landscaping (Green Acres). During
2Rule 90(f) provides in relevant part: "Any matter admitted
under this Rule is conclusively established unless the Court on
motion permits withdrawal or modification of the admission."
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