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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
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Last modified: May 25, 2011