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qualifies for relief pursuant to section 66(c); (6) whether
petitioners are liable for additions to tax pursuant to section
6651(a)(1) for failure to file timely returns; (7) whether Dr.
Beck is liable for accuracy-related penalties pursuant to section
6662(a); and (8) whether Mrs. Beck is liable for additions to tax
pursuant to section 6654(a) for underpayment of estimated taxes.2
Procedural Background
On August 28, 1998, petitioners filed their petitions with
this Court. They were then represented by John Wells (Wells).
By Court Order dated January 14, 1999, the cases were calendared
for trial at the session of the Court commencing May 17, 1999, at
Houston, Texas.
On February 1, 1999, Wells filed a motion to withdraw as
counsel. On February 3, 1999, the Court granted Wells’s motion.
After unsuccessfully attempting to secure petitioners’
cooperation in preparing a stipulation of facts, on February 19,
1999, respondent sent a letter to each petitioner, requesting
them to respond in writing to his proposed stipulations of facts
and evidence contained in 110 separately numbered paragraphs. On
the same date, respondent mailed to each petitioner and filed
2 Robert L. Beck’s (Dr. Beck’s) self-employment tax, self-
employment tax deduction, and the amounts of his allowable
personal exemption and standard deduction are computational.
Similarly, the amounts of Marguerite Beck’s (Mrs. Beck’s)
allowable personal exemption and standard deduction are
computational.
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