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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
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