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Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether petitioners are
liable for the additions to tax for negligence under section
6653(a), as determined by respondent in the notice of deficiency;
and (2) whether petitioners are liable for an addition to tax for
a substantial understatement of tax under section 6661(a), as
asserted by respondent in his answer to the amended petition.1
Background
Some of the facts have been stipulated and are so found.
The stipulations of fact and those attached exhibits which were
admitted into evidence are incorporated herein by this reference.
Petitioners resided in New Brunswick, New Jersey, on the date the
petition was filed in this case.
Petitioner husband (petitioner) earned an undergraduate
business degree from Northwestern University, an M.B.A. from
Harvard Business School, and a master of arts degree in
international economic relations from George Washington
1In the petition, petitioners argued that (1) the notice of
deficiency was issued “beyond the Statute of Limitations”; (2)
the notice “is invalid due to the fact that the Commissioner
failed to make a determination” after an examination of facts
particular to petitioners’ case; and (3) the Commissioner failed
to allow petitioners “their appeal rights within the Internal
Revenue Service”. Petitioners concede the first issue.
Petitioners did not address the remaining issues in their briefs,
and we therefore consider them to have been abandoned and need
not address them here.
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Last modified: May 25, 2011