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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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