James G. and Linda C. Jaroff - Page 9

                                        - 9 -                                         
               (15)  petitioners did not remit a proper amount of estimated           
          tax with their application for extension of time within which to            
          file their 1995 Form 1040;                                                  
               (16)  petitioners did not sign sales documents or otherwise            
          become associated with the Hoyt cattle operation until October              
          1995; and                                                                   
               (17)  petitioners were not associated with, nor did they               
          participate in, the Hoyt cattle operation in any fashion during             
          the tax year 1994.                                                          
               Items (1)-(9) and (16)-(17) of the request were also                   
          stipulated as facts by the parties.  As a consequence of the                
          deemed admissions and the stipulation of facts, petitioners                 
          conceded that they are liable for the deficiencies set forth in             
          their notice of determination.                                              
          C.   Petitioners’ Failure To Appear at Trial and Concession of              
               Their Tax Liability for 1994 and 1995                                  
               Petitioners chose not to attend their trial and did not                
          provide any testimony.  Petitioners’ counsel, Mr. Morford,                  
          entered an appearance on their behalf.  Mr. Morford explained               
          that petitioners probably had gone to work instead of appearing             
          for trial.  Mr. Morford conceded petitioners’ liability for tax             
          deficiencies of $15,535 for 1994 and $8,837 for 1995 but disputed           
          petitioners’ liability for additions to tax and accuracy-related            

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