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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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