Priscilla M. Lippincott Adams - Page 2

                                                 - 2 -                                                   

                                                       Additions to tax                                  
            Year        Deficiency               Sec. 6651(a)(1)          Sec. 6654                      
            1988        $2,111                         $522               $134                           
            1989        3,091                          273                ---                            
            1992        3,364                          160                ---                            
            1993        3,489                          226                ---                            
            1994        3,543                          199                25                             
                  Unless otherwise indicated, all section references are to                              
            the Internal Revenue Code in effect for the years in issue, and                              
            all Rule references are to the Tax Court Rules of Practice and                               
            Procedure.  The issues for decision are as follows:                                          
                  1.  Whether, pursuant to the Religious Freedom Restoration                             
            Act of 1993, petitioner is exempt from Federal income taxes.  We                             
            hold that she is not.                                                                        
                  2.  Whether petitioner is liable for additions to tax for                              
            failure to file Federal income tax returns and failure to make                               
            estimated tax payments.  We hold that she is.                                                
                  The facts have been fully stipulated under Rule 122 and are                            
            so found.  Petitioner resided in Willingboro, New Jersey, at the                             
            time she filed her petition.                                                                 
                  Petitioner is a devout Quaker and a member of the Religious                            
            Society of Friends, a Quaker organization.  Petitioner adheres to                            
            the fundamental tenets of Quaker theology, including the belief                              
            that the Spirit of God is in every person and that it is wrong to                            
            kill or otherwise harm another person.  Petitioner's faith                                   
            dictates that she not voluntarily participate, directly or                                   

Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011