- 6 - Petitioner contends that the notice of deficiency is arbitrary, unreasonable, and barred by the statute of limitations. In addition, petitioner argues that respondent should bear the burden of proof. Further, petitioner contends that he filed the Federal return and that he is entitled to either married filing joint or married filing separate status, a dependency exemption deduction for his daughter, and various Schedule A itemized deductions. Further, petitioner argues that he did not understate his 1983 Federal income tax and is not liable for the additions to tax under sections 6651(a)(1), 6653(a), 6654(a) and 6661(a). Respondent contends that petitioner failed to file the Federal return. Respondent now concedes that petitioner was married in 1983 and that only one-half of the income earned by him is taxable to him in accordance with the community property laws of California. Further, respondent contends that petitioner has not proven entitlement to any Schedule A itemized deductions nor the exemption deduction for his daughter, and that petitioner is liable for the additions to tax under sections 6651(a)(1), 6653(a), 6654(a), and 6661(a). 4(...continued) taxes, additions to tax, and interest for the taxable years 1979, 1980, and 1981.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