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pursuant to section 6651(a)(1).1 The issues for our
consideration are: (1) Whether petitioner is liable for any
portion of the 1993 or 1994 income tax deficiencies determined,
and (2) whether petitioner is liable for additions to tax for
failing to file a return.
FINDINGS OF FACT
Petitioner, who resided in Dousman, Wisconsin, at the time
his petition was filed, was a salaried employee prior to 1993 and
such employment ended prior to 1993. Petitioner did not file a
Federal income tax return for 1993 or 1994. Respondent's agent
contacted petitioner and requested that he file returns, and
during mid-December 1995 petitioner submitted "delinquent" 1993
and 1994 returns to respondent's agent reflecting approximately
$4,000 of income for each year and then reducing such amount to
zero by claiming that such income was "non-taxable compensation".
Attached to the 1993 delinquent return was a three-page document
entitled "Affidavit and Statement", in which petitioner explained
the reasons why he believes he owes no tax and the conditions and
reasons for filing the "delinquent return".
In essence, petitioner's explanation is that no section of
the Internal Revenue Code requires him to pay income tax and the
1 All section references are to the Internal Revenue Code in
effect for the years under consideration, and all Rule references
are to this Court's Rules of Practice and Procedure, unless
otherwise indicated.
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