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to tax under section 6651(a)(1) are based on respondent's
determination that petitioner's failure to file timely income tax
returns for 1991 and 1992 was not due to reasonable cause. The
additions to tax under section 6654(a) are based on respondent's
determination that petitioner failed to pay the requisite amount
of estimated income taxes for each of the years in issue.2
Petitioner's Petition and Amended Petition
Petitioner filed an imperfect petition for redetermination
on June 26, 1995, attaching thereto the first page of the two
notices of deficiency described above. The imperfect petition
states:
I WOULD LIKE TO PETITION THIS NOTICE OF DEFICIENCY AND
ALL OF THE OTHER LIENS (LIES) & CRIMINAL ACTS THAT THE
INTERNAL REVENUE SERVICE HAS COMMITTED AGAINST ME.
IF YOU PEOPLE OPERATE LIKE THE "GESTAPO" TYPE
INDIVIDUALS THAT I HAVE BEEN DEALING WITH IN THE PAST--
THIS TOO IS A WASTE OF TIME, BECAUSE THE "TAX COURT"
HAS TO BE WHY THE TERM [deletion in original]
ORIGINATED IN THE FIRST PLACE.
UNTIL YOU RETURN THE PROPERTY THAT HAS BEEN STOLEN FROM
ME I SEE NO REASON TO DEAL WITH YOU ON ANY LEVEL.
ACCORDING TO YOUR OWN CODE--SECTION 7806(b)
CONSTRUCTION OR TITLE--THE INTERNAL REVENUE CODE HAS
"NO LEGAL EFFECT."
A legend is stamped on the petition just above petitioner's
signature which states: "With express reservation of all my
2 The notices of deficiency indicate that petitioner is
entitled to prepayment (withholding) credits in the amounts of
$1,438 and $3,211 for the taxable years 1991 and 1992,
respectively.
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Last modified: May 25, 2011