David White - Page 2

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          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.                                                      




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