Thomas S. Russo - Page 4




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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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