Stephen V. Talmage - Page 2

                                         -2-                                          
               Except where otherwise indicated, all section references are           
          to the Internal Revenue Code in effect for the year in issue, and           
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
                                     Background                                       
               This case is before the Court on various outstanding                   
          motions.  The issues for decision are:  (1) Whether to grant                
          respondent's motion to dismiss for lack of prosecution; (2)                 
          whether to grant petitioner's motion for summary judgment; and              
          (3) whether to grant respondent's motion for a section 6673                 
          penalty.                                                                    
               When petitioner Stephen V. Talmage filed his petition in               
          this case, he resided in Piedmont, South Carolina.                          
               Petitioner, an employee of United Parcel Service, Inc.                 
          (UPS), filed no Federal income tax return for 1991.  On the basis           
          of statements sent to respondent by the payors, respondent, in              
          her notice of deficiency, dated October 7, 1994, attributed to              
          petitioner wages of $41,520 from UPS, nonemployee compensation of           
          $24,801 from Matol Botanical International, Montreal, Canada, and           
          dividend income of $60 from the Common Sense Growth Fund.                   
               In his petition, filed January 5, 1995, petitioner asserted            
          various tax protester arguments (e.g., that he was not subject to           
          the jurisdiction of the Internal Revenue Service; that he was not           
          a taxpayer or person as defined in the Code; and that tax forms             
          issued by Internal Revenue Service failed to display OMB numbers            




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