Dennis E. Runkle and Debra A. Runkle - Page 16

                                       - 16 -                                         
                                     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                     






Page:  Previous  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  Next

Last modified: May 25, 2011