James D. and Rita K. Snyder - Page 4




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               Whether the exemptions claimed by petitioners must be                  
          reduced on account of any increase in their adjusted gross                  
          income.4                                                                    
               Whether petitioners are liable for accuracy-related                    
          penalties under section 6662(a).                                            
               Finally, we must decide whether petitioners are liable for a           
          penalty under section 6673(a)(1).                                           
                                  FINDINGS OF FACT                                    
               Some facts are stipulated and are so found.  The first and             
          second stipulations of facts, filed by the parties, with                    
          accompanying exhibits, are incorporated herein by this reference.           
          Residence                                                                   
               At the time the petition was filed, petitioners resided in             
          Paso Robles, California.                                                    
          Complete Connections                                                        
               In 1985, petitioner Rita Snyder (Rita Snyder) applied to the           
          City of El Paso de Robles, California (the city), for a business            
          license.  On the application form for that license (the                     
          application), she stated that she was the owner of the business             
          in question, its name was “Complete Connection”, and the type of            
          business to be licensed was “business services”.  In 1988, she              
          responded to a questionnaire from the city with respect to that             


               4  This also is a computational matter, which petitioners              
          have not separately challenged, and we will not further discuss             
          it.                                                                         




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