Bruce M. Crow - Page 4

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          determinations for both 1991 and 1992 include adjustments for               
          self-employment tax under section 1401 and tax on premature                 
          distributions from individual retirement accounts under section             
          72(t).                                                                      
          The penalty under section 6662(a) and (c) is based on                       
          respondent's determination that the underpayment of tax on                  
          petitioner's 1991 tax return is due to negligence or disregard or           
          rules or regulations.  The addition to tax under section                    
          6651(a)(1) is based on respondent's determination that                      
          petitioner's failure to timely file an income tax return for 1992           
          was not due to reasonable cause.  The addition to tax under                 
          section 6654(a) is based on respondent's determination that                 
          petitioner failed to pay the requisite amount of estimated income           
          taxes for 1992.                                                             
          Petitioner filed an imperfect petition on January 30, 1995.2                
          Petitioner filed an amended petition on February 6, 1995, as                
          directed by an Order of the Court dated February 1, 1995.  The              
          amended petition states in pertinent part:                                  
               Notice of Deficiency is fraudulent, as it is based on a                
               Virgin Islands, Non-taxable return, per transaction                    
               code 150 and DLN posted to petitioner's IMF pursuant to                
               IRM3.                                                                  
          Respondent filed an answer to the amended petition on April 5,              
          1995.  Petitioner then filed a reply to respondent's answer,                

          2  At the time the petition was filed, petitioner resided at                
          Richmond, Va.                                                               




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