- 2 -- 2 - 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, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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