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Background
Petitioners failed to file Federal income tax returns for
1997, 1998, and 1999. On May 25, 2001, respondent issued to each
petitioner a notice of deficiency for those years. Relying on
Forms W-2, Wage and Tax Statement, and Forms 1099 information,
respondent determined deficiencies in petitioners’ Federal income
taxes as follows:
Michael T. Hawkins
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1997 $8,291.00 $1,074.75$206.27
1998 7,852.00 1,621.75 289.88
1999 8,435.80 1,311.20 236.68
Janine M. Hansen
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1997 $1,255.00 $313.75--
1998 848.00 212.00 --
1999 848.00 212.00 --
Petitioners resided in Sparks, Nevada, on August 23, 2001, when
they timely filed their petition.
On October 12, 2001, respondent filed an Answer. On March
15, 2002, respondent then filed a Motion for Summary Judgment
(summary judgment motion). On April 22, 2002, petitioners filed
a Response to Motion for Summary Judgment (response to summary
judgment motion) and a Motion to Dismiss for Lack of Jurisdiction
(jurisdiction motion). The Court heard the motions together, and
at the conclusion of the hearing respondent made an oral Motion
to Impose a Penalty under Section 6673 (penalty motion). The
parties did not enter into a stipulation of facts.
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Last modified: May 25, 2011