- 10 - Whether the C. Shirleys are liable for penalties under sections 6662(a) and 6673(a)(1). FINDINGS OF FACT Some facts have been stipulated and are so found. The stipulations of facts filed by the parties, with accompanying exhibits, are incorporated herein by this reference. The J. Shirleys are deemed to have admitted certain facts on account of their failure to respond to respondent’s request for admissions. See Rule 90(c). Such facts deemed admitted are conclusively established for purposes of this action (with respect to the J. Shirleys) and are incorporated herein by this reference. Residences The J. Shirleys and C. Shirleys resided in California when their petitions herein were filed. Respondent’s Examinations Prior to determining deficiencies in both the J. and C. Shirleys’ 1995 taxes, respondent examined their 1995 Federal income tax returns. In the course of that examination, respondent’s agent requested a meeting with the J. and C. Shirleys, at which they were to produce books and records used to 5(...continued) computational matters, the resolution of which will depend upon our disposition of the other issues. The C. Shirleys have not separately challenged such liability and deduction, and we shall not further discuss those items.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011