Glenn S. Hodges - Page 4

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               06/30/00       Qwest Communications Intl.         46                   
               02/01/00       SBC Communications Inc.            8,637                
               02/03/00       SBC Communications Inc.            46                   
               02/03/00       SBC Communications Inc.            46                   
               02/04/00       SBC Communications Inc.       44,594                    
               02/04/00       U.S. West Inc.                     5,011                
               Petitioner also received ordinary dividends and capital                
          gains in the amounts of $13,572 and $11,378, respectively.                  
                                       OPINION                                        
          I.  Introduction                                                            
               We first address petitioner’s constitutional challenge to              
          the income tax.  We then determine petitioner’s gain from the               
          sale of the securities.  Finally, we address the additions to tax           
          and section 6673 penalty.                                                   
          II.  Petitioner’s Constitutional Challenge to the Income Tax                
               In the amended petition, in support of his assignments of              
          error, petitioner claims that he has books and records                      
          substantiating his deductions, business expenses, credits, and              
          charitable contributions.  At the trial of this case, petitioner            
          conceded that, during 2000, the sale of the securities produced             
          proceeds of $225,390 and he received ordinary dividends and                 
          capital gains in the amounts of $13,572 and $11,378,                        
          respectively.  He offered nothing to show any business expenses,            
          credits, or charitable contributions.  He conceded that he did              
          not file a tax return for 2000.  His wife, apparently speaking              
          for him, claimed that, even if the Court were to find that he had           







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