- 12 - Petitioner, although unmarried in 1994, has not met the requirements to file as head-of-household. Petitioner did not maintain the requisite household for Douglas; petitioner’s ex- wife maintained the Aliso Viejo residence. To address petitioner’s argument that it is discriminatory to tax individuals differently, we observe that the constitutionality of different tax rates for differently situated taxpayers has been consistently upheld. Jansen v. United States, 567 F.2d 828 (8th Cir. 1977); Barter v. United States, 550 F.2d 1239 (7th Cir. 1977); Shinder v. Commissioner, 395 F.2d 222 (9th Cir. 1968), affg. per curiam T.C. Memo. 1967-73. Accordingly, we sustain respondent on this issue. Addition to Tax Under Section 6651(a) Respondent received petitioner’s 1994 tax return on August 18, 1995. The tax return was due April 15, 1995. Sec. 6072(a). Petitioner contends that he timely filed Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, requesting a 4-month extension for filing his 1994 tax return. Petitioner provided a copy of this form, dated April 15, 1995, to the Court. Petitioner did not provide any proof of mailing this request. Respondent contends that the InternalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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