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All the above-mentioned income tax returns reflected
balances due. Neither petitioner nor Mr. Ogonoski paid the
balances due when they filed their returns for the taxable years
1989 through 1999. A substantial portion of the unpaid balances
is attributable to Social Security self-employment tax on Mr.
Ogonoski’s excavation business. There is no record evidence Mr.
Ogonoski promised petitioner he would pay the tax liabilities
reported on their returns. Some payments were subsequently made
in respect of the amounts shown due on these returns. Respondent
accepted as filed all the returns for the years in issue.
The balances due, petitioner’s wages, and income tax and
Medicare and Social Security payments withheld from petitioner’s
wages, reflected on petitioner’s and Mr. Ogonoski’s joint income
tax returns, were as follows:
Medicare/Social
Balance Petitioner’s Income Tax Security Tax
Year Due Wages Withheld Withheld
1989 $8,943.18 $5,115.25 $67.87 $384.17
1990 7,696.89 4,966.80 -0- 379,96
1991 2,995.76 5,319.00 -0- 406.90
1992 5,474.30 3,355.96 32.75 256.76
1993 4,333.32 8,233.46 954.26 629.84
1994 2,242.57 14,104.65 1,151.04 1,079.05
1995 2,211.52 22,031.54 2,696.67 1,685.33
1996 3,023.28 25,302.31 3,476.39 1,935.49
1997 2,621.75 29,547.44 4,330.30 2,264.44
1998 3,647.39 33,519.15 5,336.74 2,598.56
1999 1,831.50 36,015.24 6,137.84 2,801.81
On the following dates, respondent assessed income tax,
estimated tax and failure-to-pay penalties, and interest against
petitioner and Mr. Ogonoski for the taxable years 1989 through
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