- 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