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taxable years 1991 and 1992; (3) whether petitioner is liable for
additions to tax for failure to timely file returns under section
6651(a) for the taxable years 1991 and 1992; and (4) whether
petitioner is liable for accuracy-related penalties pursuant to
section 6662(a) for the years in issue.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Milwaukee, Wisconsin.
A. Background
Petitioner graduated from Milwaukee Area Technical College
(Technical College), a 2-year college. At the Technical College,
petitioner studied business data processing and business
management. After completing Technical College, petitioner
worked in data processing. She also participated in classes
provided by the Small Business Administration, including courses
in basic accounting, management, and other skills related to
small business. During the years in issue petitioner was not
married.
B. History of Petitioner’s Cleaning Business
Prior to 1987, petitioner operated a residential and office
cleaning business called “Quest Cleaning” in Aurora, Colorado.
Petitioner moved back to Milwaukee in 1987 and changed the name
of the cleaning business to “Dustbusters Janitorial Services”
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