- 4 - 3. Whether petitioner, pursuant to section 6653(a), is liable for an addition to tax for negligence relating to his 1979 tax year. We hold that he is liable. FINDINGS OF FACT Petitioner resided in Gerona, Spain, at the time his petition was filed. During the years in issue, he was employed by Measurex Corp. (Measurex), a California corporation, and by Saab-Totem, Inc. (Saab-Totem), a Washington corporation. In 1980, petitioner received a $5,845 vacation allowance from Measurex and realized a $328,455.37 long-term capital gain attributable to the sale of 12,500 shares of Measurex stock. During that year, he also submitted to Measurex and Saab-Totem Forms W-4E. On these forms petitioner stated, under penalties of perjury, that he incurred no income tax liability for 1979 and that he anticipated no income tax liability for 1980. Petitioner submitted to respondent two tax forms relating to 1979 and three tax forms relating to 1980. On April 18, 1980, and April 17, 1981, respondent received Forms 1040 relating, respectively, to petitioner's 1979 and 1980 tax years. Petitioner, on these forms, provided objections, based on the Fifth Amendment privilege against self-incrimination, to the tax return filing requirement. After receiving these forms, the Internal Revenue Service (IRS) began investigating petitioner's 1979 and 1980 tax liability. On August 13, 1981, petitioner wrote a letter to Don Waite, an employee of Measurex, suggestingPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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