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and adopts the Opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This case is before the Court
on (1) Respondent's Motion To Dismiss For Failure To State A
Claim And To Impose A Penalty Under I.R.C. � 6673, filed pursuant
to Rule 40, and (2) Petitioner's Motion For Dismissal For Lack Of
Jurisdiction.
Petitioner resided in Phoenix, Arizona, at the time that his
petition was filed with the Court.
Respondent's Notices of Deficiency
By statutory notices dated October 5, 1995, respondent
determined deficiencies in, and additions to, petitioner's
Federal income taxes as follows:
Additions to tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1987 $262 $100 ---
1989 3,760 940 $254
1990 9,601 2,400 633
1991 763 116 ---
The deficiencies in income taxes are based on respondent's
determination that during the taxable years in issue, petitioner
received the following amounts of unreported income:
Income 1987 1989 1990 1991
Wages --- --- --- $5,115
Schedule C $2,130 $16,125 $33,873 2,944
Interest 996 37 22 ---
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