- 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 penalties.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011