Charles J. and Francesca C. Sigerseth - Page 2




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          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, respondent           






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