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Petitioner Ronald Joling
Additions to Tax
Year Deficiency Sec. 6651(a)(1)1 Sec. 6654
1994 $321,469 $80,367.25 $16,681.58
1995 305,884 76,471.00 16,585.83
1996 202,367 45,532.58 10,771.06
Petitioner Dorthea Joling
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1994 $61,332 $15,333.00 $3,182.64
1995 81,511 20,377.75 4,419.71
1996 64,530 14,519.25 3,434.63
1 Respondent also determined that each petitioner is liable,
for each taxable year, for an addition to tax under sec.
6651(a)(2) in an amount to be computed.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the periods under
consideration.
Petitioners did not file returns, contending that their
sources of income were not taxable. After respondent determined
tax deficiencies, petitioners brought forward documentation in an
attempt to show that they are entitled to deductions, if it is
decided that their income is from a source that is taxable.
Petitioners have moved for partial summary judgment on the legal
question of whether income from several sources, including their
trucking business, motel business, real estate sale, and bank
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Last modified: May 25, 2011