- 5 - 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.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011