- 3 - 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”.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011