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section 6651(a), and additions to tax of $2,576 and $1,559 under
section 6654. As to the same years, respondent determined in a
notice of deficiency issued to Cindy R. Lobe (Ms. Lobe) that she
was liable for deficiencies of $15,062 and $7,761, failure to
file additions to tax of $3,754 and $1,746 under section 6651(a),
and additions to tax of $814 and $413 under section 6654.
Following a trial at which petitioners choose neither to
testify nor to present any exhibits (with the exception of the
subject notices of deficiency which were attached to the
stipulation of facts), we must decide whether respondent’s
determinations are correct. We hold they are to the extent
described herein. Section references are to the Internal Revenue
Code in effect for the years in issue. Rule references are to
the Tax Court Rules of Practice and Procedure. Dollar amounts
have been rounded to the nearest dollar.
FINDINGS OF FACT
Some facts have been stipulated and are so found. The 16
stipulated facts and two exhibits submitted therewith are
incorporated herein by this reference. Petitioners are husband
and wife who resided together in Omak, Washington, during all
relevant years. Neither of them has filed a 1995 or 1996 Federal
income tax return.
During 1995, petitioners earned interest income of $367 from
a credit union (CU) account in which both petitioners had
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