Allen and Mary Doxtator - Page 3

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          of $4,516, or $1,090 as conceded by respondent; (8) whether                 
          petitioners are liable for an accuracy-related penalty under                
          section 6662(a) based on a substantial understatement of income             
          tax or on negligence for 1997 and 1999; and (9) whether                     
          petitioners are liable for the accuracy-related penalty under               
          section 6662(a) based on negligence for 2000.  In addition,                 
          petitioners challenge our jurisdiction to decide certain of the             
          foregoing issues, as more fully discussed infra.                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are incorporated            
          by this reference.3                                                         
               Petitioners resided in Wisconsin at the time they filed the            
          petition in this case.  Petitioners are husband and wife and                
          filed joint Federal income tax returns for 1997, 1999, and 2000.            
          Petitioners are Native Americans and members of the Oneida Tribe.           
          Compensation for Services as Judicial Officer                               
               In 1997, 1999, and 2000, Mrs. Doxtator worked for the Oneida           
          Tribe as a "judicial officer" of the Oneida Appeals Commission              
          and the Oneida Personnel Commission.  The business of the Oneida            
          Tribe is run by a business committee.  Mrs. Doxtator was                    
          appointed to the position of judicial officer for a 3-year term             


               3 A portion of the transcript of the trial proceedings in              
          this case was lost because of errors of the reporting service.              
          As a consequence, the parties entered into a supplemental                   
          stipulation of facts as an agreed substitute in lieu of any other           
          remedy.                                                                     




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