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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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