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We must decide:
1 Whether petitioners are liable for the deficiencies
determined by respondent. We hold they are.
2. Whether petitioners are liable for the additions to tax
under section 6651(a)(1). We hold they are.
3. Whether petitioners are liable for the additions to tax
under section 6654. We hold they are.
FINDINGS OF FACT
Some facts were stipulated, and we incorporate by this
reference the parties’ stipulation of facts and the accompanying
exhibits. We find those facts accordingly. Petitioners are
husband and wife, and they resided in Texas, a community property
State, at all relevant times.
During 1994, Mr. Burnett was employed by and received wages
from Lubbock Independent School District (Lubbock). He received
from Lubbock $22,139 of wages in its 1993/1994 school year, of
which $16,177 was received in 1994. He also received wages from
Lubbock in September, October, and November of 1994. The net
(take-home) amount of these wages was $910, $930, and $164,
respectively.
Mr. Burnett is the owner and publisher of a weekly newspaper
(newspaper) named “The Post Dispatch”.4 He had originally sold
4 Petitioner also printed a magazine (magazine) known as the
“Republic of Texas”.
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