Diane Marie Murdoch - Page 3




                                        - 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 to              





Page:  Previous  1  2  3  4  5  Next

Last modified: May 25, 2011