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The issues for decision are:
(1) Whether petitioner had unreported income for the year
1990, as determined by respondent. We hold she did.
(2) Whether petitioner is liable for a section 6651(a)
addition to tax for failure to file a 1990 Federal income tax
return. We hold she is.
(3) Whether petitioner is liable for a section 6654(a)
addition to tax for failure to make estimated tax payments for
1990. We hold she is.
(4) Whether petitioner should be required to pay a penalty to
the United States under section 6673(a)(1). We hold she should, in
the amount of $2,500.
All section references are to the Internal Revenue Code in
effect for the year 1990. All Rule references are to the Tax Court
Rules of Practice and Procedure.
FINDINGS OF FACT
Despite the Court's request, no stipulation of facts was
filed. Petitioner called no witnesses. Rather, petitioner relied
on her trial memorandum, which contains nothing more than tax
protester rhetoric and legalistic gibberish. Petitioner did,
however, testify. She did so as respondent's sole witness. For
the most part, petitioner's testimony was in connection with
respondent's request for a penalty pursuant to section 6673(a)(1).
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