Frederick M. Fox - Page 2

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                    impose a penalty against petitioner under section 6673 in the                                                                                          
                    amount of $7,500.                                                                                                                                      
                              Respondent determined deficiencies in petitioner's income                                                                                    
                    taxes and additions to tax as follows:                                                                                                                 
                                                                                Additions to tax                                                                           
                              Year                Deficiency                    Sec. 6651(a)(1)                         Sec. 6654                                          
                              1989                $34,925                       $8,731                                  $2,362                                             
                              1990                31,218                        7,805                                   2,057                                              
                              1991                40,067                        10,017                                  2,307                                              
                              1992                42,552                        10,638                                  1,858                                              
                                                                           Background                                                                                      
                    A.        Petitioner                                                                                                                                   
                              Petitioner lived in Irvine, California, when he filed the                                                                                    
                    petition in this case.                                                                                                                                 
                              Petitioner previously petitioned this Court in cases decided                                                                                 
                    at Fox v. Commissioner, T.C. Memo. 1989-232, affd. without                                                                                             
                    published opinion 943 F.2d 55 (9th Cir. 1991) (Fox I); Fox v.                                                                                          
                    Commissioner, T.C. Memo. 1993-37 (Fox II); and Fox v.                                                                                                  
                    Commissioner, T.C. Memo. 1993-277, affd. without published                                                                                             
                    opinion 69 F.3d 543 (9th Cir. 1995) (Fox III).  Petitioner's                                                                                           
                    positions in the previous cases were frivolous and groundless.                                                                                         
                    In Fox I and Fox III, we awarded penalties to the United States                                                                                        
                    under section 6673 on our own motion.                                                                                                                  
                    B.        Petition                                                                                                                                     
                              In the petition, petitioner contended respondent erred in                                                                                    
                    determining:  (1) He was liable for deficiencies and additions to                                                                                      
                    tax; (2) his wages, interest, dividends, capital gains, and                                                                                            




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