Elmer P. Scheckel - Page 5




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          pertaining to unmarried (single) individuals and allowed                    
          petitioner one personal exemption and the applicable standard               
          deduction.                                                                  
               The additions to tax under section 6651(a)(1) are based on             
          respondent's determination that petitioner's failure to file for            
          1996 and 1997 was not due to reasonable cause.  The additions to            
          tax under section 6651(a)(2) are based on respondent’s                      
          determination that petitioner’s failure to pay his tax liability            
          for 1996 and 1997 was not due to reasonable cause.  Finally, the            
          additions to tax under section 6654(a) are based on respondent's            
          determination that petitioner failed to pay the requisite amount            
          of estimated taxes for 1996 and 1997.                                       
               On June 8, 2000, petitioner timely filed a petition for                
          redetermination.  See sec. 6213(a).                                         
          Discussion                                                                  
               At trial, petitioner stated that he did not dispute any of             
          the income amounts determined by respondent in the notice of                
          deficiency.2  Rather, petitioner took the position that “The                
          income items are irrelevant.”  In addition, petitioner alleged              
          that the Government has shown him nothing that “connects me with            



               2  Indeed, in the petition, petitioner did not set forth any           
          assignments of error nor any statements of fact.  See Rule                  
          34(b)(4) (“Any issue not raised in the assignments of error shall           
          be deemed to be conceded.”); see also Rule 34(b)(5); cf. Parker             
          v. Commissioner, 117 F.3d 785 (5th Cir. 1997); White v.                     
          Commissioner, T.C. Memo. 1997-459.                                          





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