Wayne D. Bumgarner - Page 1

                                         T.C. Memo. 1997-48                                              

                                      UNITED STATES TAX COURT                                            

                      WAYNE D. BUMGARNER, Petitioner v. COMMISSIONER OF                                  
                                   INTERNAL REVENUE, Respondent                                          

                  Docket No. 407-95.                   Filed January 27, 1997.                           

                        P instituted this proceeding claiming that his                                   
                  wages and nonemployee compensation are not income                                      
                  subject to tax.  Held:  R's determinations of income                                   
                  tax deficiencies and additions to the tax under secs.                                  
                  6651(a) and 6654(a), I.R.C., are sustained.  Held,                                     
                  further, on the Court's own motion P must pay a penalty                                
                  to the United States in the amount of $1,000 since P's                                 
                  position in this proceeding is frivolous and                                           
                  groundless.  Sec. 6673(a), I.R.C.                                                      

                  Wayne D. Bumgarner, pro se.                                                            
                  Shirley M. Francis, for respondent.                                                    

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