Wayne Curtis Siron - Page 2

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          respondent, whether petitioner is liable for the additions to tax           
          as determined by respondent, and whether petitioner is liable for           
          a penalty under section 6673.  All section and Code references              
          are to the Internal Revenue Code, as amended, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            
                                     Background                                       
               The facts in this case have been established by the Court’s            
          order of December 28, 2005.1  At the time of filing the petition,           
          petitioner resided in Blythewood, South Carolina.  Petitioner was           
          married to Rose Siron throughout 1998.                                      
               During 1998, petitioner received compensation from FN                  
          Manufacturing, Inc. (FN Manufacturing), of $27,011.27 and                   
          received compensation from the State Board of Technical and                 
          Comparative Education (the State Board) of $323.  FN                        
          Manufacturing and the State Board each issued petitioner a                  
          1998 Form W-2, Wage and Tax Statement, reflecting those                     
          payments.  FN Manufacturing withheld zero Federal income taxes              





               1As discussed below, on Nov. 18, 2005, respondent filed a              
          motion to show cause why proposed facts and evidence should not             
          be accepted as established pursuant to Rule 91(f).  On Nov. 21,             
          2005, we granted respondent’s motion and further ordered                    
          petitioner to file a response in compliance with Rule 91(f)(2) or           
          respondent’s proposed stipulations would be deemed established              
          and an order would be entered pursuant to Rule 91(f)(3).                    
          Petitioner never responded to our order, and, accordingly, we               
          ordered the facts deemed established on Dec. 28, 2005.                      




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