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The issues for decision are: (1) Whether petitioner
received taxable wage and pension income during each of the years
in issue; (2) whether petitioner is liable for additions to tax
under section 6651(f)1 for fraudulent failure to file income tax
returns for the years in issue; and (3) whether petitioner is
liable for the additions to tax under section 6654(a) for failure
to pay estimated tax for the years in issue.
When this case was called for trial, respondent moved,
pursuant to Rule 91(f), to compel petitioner to enter into a
proposed stipulation of facts. After hearing the parties on the
motion, we determined that there was no real dispute about the
facts proposed for stipulation and that there was no good reason
why the facts and exhibits attached to the stipulation should not
be made part of the evidentiary record. We therefore granted
respondent’s motion and deemed the matters contained in the
proposed stipulation to be facts for purposes of this case. See
Rule 91(f). After we granted the motion, the parties decided
that they would not call any witnesses, and the case was
submitted on the stipulated facts.
1Unless otherwise indicated, 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.
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Last modified: May 25, 2011