- 2 - interest. We hold he did not. Unless otherwise indicated, section references are to the applicable versions of the Internal Revenue Code. Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some facts were stipulated. We incorporate herein by this reference the parties’ stipulation of facts and the exhibits submitted therewith. We find the stipulated facts accordingly. Petitioners are husband and wife. They resided in Hastings, Michigan, when their petition was filed with the Court. Petitioners filed timely 1990 and 1991 joint Federal income tax returns and paid the reported taxes. Respondent audited those returns in 1993 and disallowed certain claimed business expenses. Respondent’s disallowance of these expenses increased petitioners’ tax liability for 1990 and 1991. Respondent also determined during the audit that petitioners were liable for 1990 and 1991 accuracy-related penalties under section 6662(a). On September 17, 1993, petitioners agreed to the assessment of the amount of taxes and penalties determined by respondent. Subsequently, on several occasions, petitioners offered to respondent a compromise of the amount of those assessed amounts. Respondent rejected each of these offers. On December 28, 2000, petitioners filed with respondent Forms 843, Claim for Refund and Request for Abatement, for 1990Page: Previous 1 2 3 4 5 Next
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