Shirley J. Raney - Page 2




                                        - 2 -                                         
                Additions to Tax                                                      
               Year     Deficiency     Sec. 6651(f)   Sec. 6654(a)                    
               1992      $2,226           $1,568          $91                         
               1993       1,721            1,291           72                         
               1994       4,237            1,741          109                         
               1995       2,668            1,360           93                         
               1996       2,126            1,498          106                         
               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               


               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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