- 2 - 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)", andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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