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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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