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thereof during which the petitioner fails to pay, not exceeding
25 percent in the aggregate.
The issues for decision are whether petitioner is liable for
additions to tax under sections 6651(a)(1), (2), and 6654(a) for
1996, 1997, and 1998.
Some of the facts, including the correct amounts of
petitioner’s income for the years in issue and the correct
amounts of deficiencies, have been stipulated and are so found.
The stipulation of facts and the accompanying exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Pittsburg, California.
Background
Petitioner and his former wife, Sylvia Russo (Sylvia), are
the parents of two sons, Salvatore and Anthony. Petitioner and
Sylvia separated in October 1995 and subsequently divorced.
Petitioner and Sylvia shared joint custody of their sons, with
Sylvia having primary physical custody. In 1997 petitioner
married Belinda Russo, to whom he was married at the time of
trial.
In May or June of 1999, Sylvia allegedly refused to allow
Salvatore and Anthony to visit petitioner. Later that summer,
petitioner’s sons informed him that Sylvia had been verbally and
physically abusing them. Petitioner contacted an attorney in
order to seek temporary physical custody of his sons.
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