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6651(a)(1) for 2000 and 2001, (3) whether petitioner is liable
for the addition to tax pursuant to section 6654(a) for 2001, and
(4) whether to impose a penalty pursuant to section 6673.
FINDINGS OF FACT
None of the facts have been stipulated with the exception
that at trial petitioner stipulated at the time he filed his
petition he resided in Lakewood Village, Texas.3
I. 1998 and 1999
Petitioner and his wife, Laurie G. Guthrie, filed joint
Federal income tax returns for 1998 and 1999. On their 1998
return, petitioner and his wife reported, among other things,
wages of $132,330, taxable interest of $655, ordinary dividends
of $220, a loss from rental real estate of $8,398, adjusted gross
income of $124,807, taxable income of $95,153, tax of $21,144,
total tax of $20,938, Federal income tax withheld of $15,410, and
an amount owed of $5,528. Attached to their 1998 return were
Forms W-2, Wage and Tax Statement, for petitioner and his wife
from Electronic Data Systems (EDS) listing wages of $84,203.68
and $48,125.93 for petitioner and his wife, respectively.
Petitioner and his wife signed their 1998 return on April 14,
1999. On the 1998 return, petitioners stated it was “self-
3 The Court admonished petitioner that certain facts and
documents should not be in issue, such as whether he filed
returns and where he lived when he filed the petition.
Petitioner, however, asserted a Fifth Amendment claim as the
basis of his refusal to stipulate facts.
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