- 2 -
and adopts the opinion of the Special Trial Judge, which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This matter is before the Court
on respondent's Motion to Dismiss for Failure to State a Claim
Upon Which Relief Can Be Granted. As explained in greater detail
below, we shall grant respondent's motion.
Background
Respondent issued a notice of deficiency to petitioner
determining deficiencies in and additions to his Federal income
taxes for the years and in the amounts as follows:
Additions to tax
Year Deficiency Sec. 6651(a) Sec. 6654(a)
1992 $10,902 $1,163 --
1993 20,659 5,165 $866
1994 10,269 2,567 $533
The notice of deficiency includes an explanation that the
adjustments to petitioner's taxable income are attributable to
petitioner's failure to file tax returns reporting various items
of income including: (1) Nonemployee compensation paid by
Lincoln Investment Planning, General American Life, and Willow
Fork Drainage District; (2) interest paid by Charles Schwab &
Co., First City Texas, and Texas Commerce Bank; (3) dividends
1(...continued)
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011