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(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.
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