- 2 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011