- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011