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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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