Charles Vernon Roberts - Page 2

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          under sections 6653(a), 6651(a)(1), 6661(a), and 6654(a) in the             
          amounts of $289.85, $1,449.25, $579.70, and $354.89,                        
          respectively.                                                               
               The issues for decision are:  (1) Whether petitioner filed             
          his 1983 Federal income tax return; (2) whether respondent should           
          bear the burden of proof in this case because her position in the           
          notice of deficiency was arbitrary and unreasonable; (3) whether            
          respondent is barred by the statute of limitations from                     
          proceeding to assess and collect the 1983 tax liability; (4)                
          whether petitioner is entitled to joint filing status; (5)                  
          whether petitioner is entitled to a dependency exemption                    
          deduction for his daughter; (6) whether petitioner is entitled to           
          certain Schedule A itemized deductions; (7) whether petitioner is           
          liable for the addition to tax under section 6651(a)(1) for                 
          failure to timely file his 1983 return; (8) whether petitioner is           
          liable for the addition to tax under section 6653(a) for                    
          negligence; (9) whether petitioner is liable for the addition to            
          tax under section 6661(a) for a substantial understatement of               
          income tax; and (10) whether petitioner is liable for the                   
          addition to tax under section 6654(a) for failure to make                   
          estimated tax payments.2                                                    

          2  In his brief, petitioner suggested 2 additional issues                   
          which border on the frivolous; viz, whether the Form 1040 is so             
          ambiguous and unintelligible so as to deprive petitioner of his             
          "due process notice pursuant to the 4th [sic] Amendment", and               
                                                             (continued...)           




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