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Mr. Runkle
Addition to Tax
Year Deficiency Sec. 6651(f) Sec. 6654
1991 $28,258 $19,703 $1,136
1992 20,162 15,122 879
1993 20,643 15,482 865
1994 10,475 7,856 540
1995 10,100 7,575 551
Mrs. Runkle
Addition to Tax
Year Deficiency Sec. 6651(f) Sec. 6654
1991 $12,881 $9,661 $562
1992 8,983 6,737 392
1993 15,206 11,405 637
1994 20,180 15,135 1,040
1995 10,951 8,213 598
Petitioners timely filed a petition with this Court for a
redetermination.
OPINION
This case presents a brazen challenge to respondent’s
determinations that the failure of two married, self-employed
individuals to file returns was fraudulent. Mr. Runkle, a tax,
financial and insurance planner, and his wife, Mrs. Runkle, a pet
kennel operator, have persistently failed to file Federal income
tax returns for 14 years since 1990. They acknowledged at trial
that the “untaxing” program they asserted throughout this case
from 1991 until as recently as their motion to dismiss, filed
February 17, 2004, has no merit. At trial, petitioners
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