- 2 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The deemed admissions, the stipulation of facts, and the attached exhibits are incorporated herein by this reference.3 At the time they filed the petition, petitioners resided in Pelham, New York. During 1995, 1996, and 1997, on his Form W-4, Employee’s Withholding Allowance Certificate, petitioner Jerome Edward Brown (Mr. Brown) claimed exemptions exceeding the number petitioners were entitled to claim on their 1995, 1996, and 1997 tax returns. Accordingly, insufficient taxes were withheld from his wages. Mr. Brown did this because he “needed the income” during the years in issue as he was in school full time, supporting his wife and three children, and his wife was not working. Petitioners did not timely file their 1995, 1996, or 1997 tax returns. On July 8, 1998, respondent prepared a substitute for return for petitioners’ 1996 income taxes. 3 Petitioners stipulated and are deemed to have admitted: (1) They are liable for the addition to tax pursuant to sec. 6651(a)(1) for 1995 and 1997; (2) they are liable for the addition to tax pursuant to sec. 6651(a)(2) for 1995; (3) they are liable for the unabated amounts of the additions to tax pursuant to sec. 6651(a)(1) and (2) for 1996; (4) they are liable for the unabated amounts of the addition to tax pursuant to sec. 6651(a)(2) for 1997; (5) they are not entitled to an abatement of interest for 1995; and (6) they are not entitled to any additional abatement of interest for 1996 or 1997.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011