Franklin Earl, Kish - Page 3

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               5.  Whether petitioner is liable for a sanction under                  
          section 6673(a).  We hold he is and require him to pay to the               
          United States a penalty of $5,000.                                          
               Section references are to the Internal Revenue Code in                 
          effect for the subject years.  Rule references are to the Tax               
          Court Rules of Practice and Procedure.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  These stipulations            
          and the exhibits submitted therewith are incorporated herein by             
          this reference.  Petitioner did not file a Federal income tax               
          return for any of the subject years.  He claims not to have had a           
          Social Security number during these years because he "rescinded"            
          the Social Security number that was given to him many years                 
          before.  Petitioner lived in West Olive, Michigan, when he                  
          petitioned the Court.                                                       
               In 1992 and 1993, petitioner worked as an employee of the              
          Grand Rapids Area Transit Authority, f.k.a. Grand Rapids City               
          Coach Lines (the Authority), and the Authority paid him wages of            
          $25,742 and $6,540 during the respective years.  Petitioner also            
          marketed biomagnetic devices in each subject year through his               
          sole proprietorship known as Universal Magnetics.                           
               Petitioner and his wife have at least two joint bank                   
          accounts at ATL Employees Credit Union (the Credit Union).  These           
          accounts are numbered 17075-2-01 and 17075-2-10.  Petitioner also           





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