Charles Vernon Roberts - Page 6

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               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.                                                             







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