- 2 - dismissed this case for lack of prosecution as to the deficiencies in petitioners' income taxes, we have remaining for decision whether petitioners are liable for the accuracy-related penalties and whether to impose a penalty under section 6673 on petitioners. Background At the time the petition was filed, petitioners resided in El Macero, California. On September 23, 1999, respondent determined that for the 1995 and 1996 tax years, petitioners failed to report income with regard to the activities of three trusts and capital gain from the sale or exchange of assets, and petitioners were not entitled to a deduction with regard to certain personal exemptions. Further, respondent determined that petitioners were liable for self-employment taxes but allowed a partially offsetting deduction for the self-employment taxes determined. Respondent additionally determined accuracy-related penalties based on a substantial understatement of tax or negligence or disregard of rules or regulations. On December 27, 1999, petitioners filed a petition in this Court, averring that respondent’s determinations were erroneous, the notice of deficiency was issued improperly, and respondent had the burden of proof with regard to the determinations made by him. On March 8, 2000, after we allowed an extension of time in which respondent could answer, respondentPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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