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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 citizen
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