Dennis R. Andrews - Page 2

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                                   Additions to Tax                                    
          Year      Deficiency     Sec. 6651(a)(1)      Sec. 6654                      
          1991      $13,997        $3,499.25            $811.54                        
          1992      10,926         2,731.50             476.54                         
          1993      9,575          2,393.75             401.18                         
          1994      9,406          2,351.50             488.12                         
               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.                                                                   
               After concessions, the issues for decision are:  (1) Whether            
          the notice of deficiency is arbitrary and excessive and therefore            
          lacks presumptive correctness; (2) whether petitioner is liable              
          for the deficiencies in taxes as determined by respondent; and               
          (3) whether petitioner is liable for the additions to tax as                 
          determined by respondent.                                                    
                                   FINDINGS OF FACT                                    
               The parties submitted the instant case fully stipulated.                
          The stipulated facts are incorporated herein by reference and are            
          found as facts in the instant case.  Petitioner resided in                   
          Warsaw, Indiana, at the time he filed his petition.                          
               In a letter to respondent dated July 18, 1994, petitioner               
          stated that he is not a resident or citizen of the United States,            
          but that he is a "Natural human being of the Indiana Republic",              
          questioned respondent's delegation of authority to operate in a              
          foreign capacity in the "united American Republic (Indiana)", and            





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