-2- Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After a concession by respondent,1 the issues for decision are: (1) Whether petitioners substantiated deductions, losses, and/or cost of goods sold in excess of amounts respondent allowed or conceded for 2002 and 2003, (2) whether petitioners are liable for self-employment tax in 2002 and 2003, (3) whether petitioners are liable for the section 6651(a)(1) addition to tax for 2003, and (4) whether petitioners are liable for the section 6662(a) penalty for 2002 and 2003. FINDINGS OF FACT None of the facts have been stipulated. Confronted with petitioners’ refusal to work toward a stipulation of facts, respondent filed, among other things, requests for admission pursuant to Rule 90. After the Court granted a motion by petitioners to extend the time for their reply to respondent’s requests for admission, petitioners did not file a response within the time permitted to respondent’s requests for admission, including the extension of time granted by the Court. 1 Respondent concedes that petitioners substantiated $3,122.52 in labor expenses for 2003 (attributable to services performed by William Ray).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007