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We decide first certain arguments made by petitioner as to
claimed improprieties in the conduct of the trial of this case.
We reject each argument. We decide second whether we have
jurisdiction over 1996 through 1998. We hold we do. We decide
third whether the disputed amounts paid to Ms. Odell were wages.
We hold they were. We decide fourth whether petitioner is
entitled to relief under section 530 of the Revenue Act of 1978,
Pub. L. 95-600, 92 Stat. 2763, 2885. We hold it is not. We
decide fifth whether petitioner is liable for the additions to
tax determined by respondent under sections 6651(a) and 6656. We
hold it is to the extent stated herein.
FINDINGS OF FACT2
Some facts were stipulated. The stipulated facts and the
exhibits submitted therewith are incorporated herein by this
reference. We find the stipulated facts accordingly. Petitioner
is a C corporation, and its mailing address was in Spirit Lake,
Idaho, when its petition was filed. Its stock is owned equally
by Ms. Odell and her husband, Theodore K. Odell (Mr. Odell)
(collectively, the Odells).3 Ms. Odell is petitioner’s president
2 Petitioner in its brief proposes that the Court find as
facts certain recitals of trial testimony. We decline to do so.
See Rule 151(e)(3).
3 Mr. Odell’s ownership interest arises entirely from
community property law.
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