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testified: "I am not a citizen of the United States. I am a
citizen of New Hampshire. Therefore, I do not * * * [have] to
file a Federal United States Federal [sic] income tax [return]."
We reject petitioner's contention and hold that petitioner is
liable for the section 6651(a)(1) addition to tax.
Finally, we consider whether petitioner has engaged in
behavior that warrants the imposition of a penalty pursuant to
section 6673. Section 6673(a)(1) authorizes this Court to
penalize a taxpayer for taking frivolous positions or instituting
proceedings primarily for delay. At the outset of the trial, we
warned petitioner that he would be subject to a penalty if he
made frivolous contentions. Nevertheless, he repeatedly asserted
that: (1) He, "Leon Albert Landry", was not the "Leon Landry" in
the notice of deficiency; (2) as a "citizen of New Hampshire", he
was not required to file a Federal income tax return; and (3) the
Internal Revenue Service "has not shown * * * [him] its lawful
authority to act against him." In addition, petitioner did not
comply with our order to answer respondent's interrogatories. He
has wasted the time and resources of this Court. Accordingly,
this Court will impose a penalty of $5,000 against petitioner
pursuant to section 6673.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011