- 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, respondent
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011