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additions to tax for failure to timely file returns under section
6651(a) for tax years 1988 to 1992; and (3) whether petitioners
are liable for an addition to tax for negligence under section
6653(a)(1) for tax year 1988. Adjustments to self-employment
income taxes and the deductions therefor, and the earned income
credits are computational and will be resolved by the Court’s
holding on the issues in these cases.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the
respective petitions were filed, petitioners resided in
Baltimore, Maryland. Petitioners Ronald and Nancy Sweet are
husband and wife. References to petitioner in the singular are
to Ronald T. Sweet.
From 1988 through 1993, petitioner was a window installation
contractor and a tax return preparer. Petitioner installed
windows for Washington Energy Corporation (Washington Energy) as
an independent contractor. Upon acceptance of a contract or
“job” from Washington Energy, petitioner would employ other
workers, if necessary.
Petitioners testified that it was a common practice in the
window installation business for a contractor receiving a payment
2(...continued)
we treat these items of cost of goods sold as additional labor
expenses. Infra.
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