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(4) Whether respondent erroneously disallowed deductions for
expenses allegedly incurred in 1996 relating to petitioner
Marilyn Sowards’s purported organizational consulting business;
(5) Whether petitioner Ray Sowards is liable for fraud
penalties pursuant to section 6663 for the taxable years 1996 and
1997;
(6) Whether petitioners are liable for accuracy-related
penalties pursuant to section 6662(a) for the taxable years 1995,
1996, and 1997;2
(7) Whether petitioners are liable for additions to tax for
failure to pay estimated tax pursuant to section 6654 for the
taxable years 1996 and 1997;3 and
(8) Whether petitioner Marilyn Sowards is entitled to relief
from joint and several liability pursuant to section 6015 for the
taxable years at issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, the second stipulation of facts, the
stipulation of settled issues, and the attached exhibits are
2Respondent determined a negligence penalty pursuant to sec.
6662(a) for 1995 premised upon the entire amount of the
deficiency. With respect to 1996 and 1997, respondent determined
negligence penalties as an alternative to the fraud penalty and
for the deficiency amounts related to lack of substantiation.
3Petitioner Ray Sowards concedes the applicability of this
addition to tax based upon the Court’s opinion and computation
under Rule 155.
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Last modified: May 25, 2011