- 2 - Respondent, in a notice of deficiency, determined against petitioner the following deficiencies in Federal income taxes and additions to tax for the years indicated: Addition to Tax Year Deficiency Sec. 6651(a)(1) 1994 $3,154 $388.00 1995 3,116 419.00 1996 2,486 390.75 1998 2,359 304.25 In a written stipulation filed by the parties, petitioner conceded all the adjustments in the notice of deficiency, except the additions to tax under section 6651(a)(1). The parties further stipulated that, in addition to the section 6651(a)(1) issue, the remaining issue was whether petitioner was entitled to deductions for trade or business expenses incurred in a dog breeding activity. Accordingly, the stipulated facts are so found, along with the exhibits annexed thereto. At the time the petition was filed, petitioner's legal residence was Riverside, California. At the time this case was called from the calendar at the opening of the trial session, petitioner appeared. At that time, she and counsel for respondent executed the stipulation referred to. However, petitioner failed to appear at the time scheduled for trial of her case. The sole evidence presented to the Court in support of petitioner's case is the stipulation referred toPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011