- 5 - In response, the Court issued an Order, dated March 30, 1995, in which we characterized petitioner's arguments as frivolous and admonished petitioner that if he continued to advance such frivolous legal arguments, we would consider imposing a penalty under section 6673. At the trial of this case, on June 10, 1996, petitioner continued the same tax protester arguments he had been warned to abandon. In the notice of deficiency, respondent determined that petitioner was liable for tax on all the wage income he received from the City and on 50 percent of the wage income Mrs. Simmons received from the hospital. Respondent also determined additions to tax under section 6651(f) for the years in issue. In respondent's posttrial brief, respondent conceded that petitioner's and Mrs. Simmons' wages were community income, and thus petitioner was liable for tax on only 50 percent of the income he received from the City, and 50 percent of the income Mrs. Simmons received from the hospital. OPINION Issue 1. Unreported Income The uncontroverted evidence in this case establishes that petitioner and Mrs. Simmons had unreported wage income during each of the years under consideration as follows: Petitioner Mrs. Simmons 1990 $28,515 $ 9,330 1991 28,481 13,081Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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