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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.
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Last modified: May 25, 2011