- 3 - under section 6651(a)(1) are based on respondent's determination that petitioner's failure to file timely income tax returns 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 estimated income tax for the years in issue. The petition, timely filed, contains the following allegations: (reproduced exactly) THE PETITIONER, UPON PRESENTMENT BY INTERNAL REVENUE, RETURNED AND REFUSED FOR CAUSE UCC 3-501 SAID PRESENTMENTS WITHOUT DISHONOR. IN ADDITION, PETITIONER MARK NAGY, IS NOT A "U.S. CITIZEN" NEITHER IS HE A 'RESIDENT NOR INHABITANT' OF THE U.S. AND HAS NO INCOME EFFECTIVELY CONNECTED WITH THE UNITED STATES THAT MARK NAGY DID NOT KNOWINGLY OR VOLUNTARILY ENTER INTO ANY AGREEMENT OR CONTRACT TO BE LIABLE FOR THE NATIONAL DEBT, OR 'ELECTED' TO BE TREATED AS A RESIDENT OF THE UNITED STATES UNDER 26 CFR PART 5h; 26 USC, SECTION 6013 (g) & (h) BY THE SIGNING OF FORM 1040 OR OTHER RELATED U.S. FORMS. MARK NAGY IS NOT A PARTY TO ANY TRANSACTION WITH THE U.S. LET THE U.S. PRODUCE THE ORIGINAL SIGNED CONTRACT [SEC.] 871 4(b) FURTHER PETITIONER SAYETH NOT. After respondent filed the instant motion to dismiss, petitioner filed an Objection in which he claims, inter alia, that self-employment tax is an "excise-taxable" activity and that 3. Petitioner is a non-resident alien for purpose of the Federal Excise Tax. * * * 6. At issue in this case is the factual error the Respondent made by classifying the Petitioner as a resident of the U.S., and that the petitioner is engaged in excise taxable activity. Since the Petitioner was/is a non resident alien and not engaged in any excise taxable activity he disputes [the deficiencies, additions to tax, and interest].Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011