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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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