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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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