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MEMORANDUM OPINION2
LARO, Judge: These cases were consolidated for purposes of
trial, briefing, and opinion. In a notice of deficiency dated
April 28, 2005, respondent determined the following deficiencies
and additions to tax with respect to John M. Smoll’s
(petitioner’s) 1999, 2002, and 2003 Federal income taxes:
Additions to Tax
Year Tax Sec. 6651(f) Sec. 6654
1999 $30,620 $22,966 $1,482
2002 118,533 88,900 3,961
2003 85,312 63,984 2,233
In a second notice of deficiency dated April 28, 2005,
respondent determined the following deficiencies, additions to
tax, and penalties with respect to petitioners’ 2000 and 2001
Federal income taxes:
Addition to Tax Penalty
Year Tax Sec. 6651(a)(1) Sec. 6663
2000 $21,930 $5,482 $16,447
2001 24,890 6,222 18,667
Respondent filed a motion to dismiss this case for lack of
prosecution, and we are left to decide the propriety of
2 We found the facts of this case from matter that was
deemed stipulated under Rule 91(f) and from testimony that was
elicited at trial. For convenience, we have incorporated our
findings of fact with our opinion. Section references are to the
applicable versions of the Internal Revenue Code, and Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded. When their petitions were filed,
petitioners resided in Sturgis, Michigan.
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