- 2 - adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE NAMEROFF, Special Trial Judge: This case is before us on respondent's Motion to Dismiss For Failure to State a Claim and to Impose a Penalty Under Section 6673. Respondent determined deficiencies in petitioner's Federal income taxes and additions to tax as follows: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1989 $2,504 $626 $168 1990 9,268 2,317 613 1991 7,136 1,784 410 1992 8,020 2,005 349 1993 6,065 1,516 256 1994 2,315 463 119 The adjustments giving rise to the above deficiencies and additions to tax are based upon the failure of petitioner to file income tax returns and report his income for the subject years. The nature of the unreported income determined by respondent in the two notices of deficiency is "nonemployment compensation" in all 6 years, plus "imputed income" for the years 1990 through 1993 based upon Bureau of Labor statistics. The gist of petitioner's allegations in his petition is that: (1) "The Commissioner and/or his delegate has erroneously and arbitrarily concluded that Frank C. Verbeck, Jr. is a citizenPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011