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deposited to his sole proprietorship, Staying Young Unlimited.
The Commissioner also determined that petitioner failed to report
income on Federal income tax returns for the taxable years 1991
and 1992. In his petition in that case petitioner asserted that
the notice of deficiency was invalid, respondent's determination
was unconstitutional, and the amounts received were not income.
On February 8, 1996, pursuant to Rule 152(b), petitioner was
served with a copy of the Court's oral findings of fact and
opinion. The Court concluded that the Commissioner's
determination was correct with respect to the deficiency and
additions to tax for 1991 and 1992. Also, the Court held in
favor of the Commissioner with respect to claimed increased
deficiencies and additions to tax.
Section 6673(a) authorizes the Tax Court to require a
taxpayer to pay to the United States a penalty not in excess of
$25,000 whenever it appears that proceedings have been instituted
or maintained by the taxpayer primarily for delay or that the
taxpayer's position in such proceeding is frivolous or
groundless.
Petitioner did not file a Federal income tax return for the
taxable year 1993. He received substantial income during the
year in issue. Petitioner filed a petition with respect to the
1991 and 1992 tax years, and the Court concluded in that case
that petitioner was liable for deficiencies for omitted income as
well as additions to tax for failure to file a return and failure
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