Gaylon L. Harrell - Page 4

          public accountant about petitioner’s duty to file a tax return              
          for 1993.  Petitioner’s failure to file tax returns since 1979 is           
               During 1993, petitioner had wage income from the USPS in the           
          amount of $23,371.94, from which there was withheld $3,389.83               
          income tax, $1,449.06 Social Security tax, and $338.89 Medicare             
          tax.  Petitioner also received pension distributions from the               
          Caterpillar NCP Trust in the amount of $15,720 during 1993.                 
               Petitioner has not had a bank account in his name since                
          about the mid-1980’s.  For about 10 years, including 1993,                  
          petitioner had his paychecks deposited into a checking account in           
          the name of his adult son, Randy.  Petitioner does not have                 
          signatory authority over this checking account.  Randy wrote                
          checks on this checking account to petitioner, petitioner cashed            
          the checks, and petitioner then used the currency obtained                  
          thereby to pay his expenses.                                                
               The petition and amended petitions that petitioner filed in            
          the instant case raised frivolous contentions that resulted in              
          this Court’s granting partial judgment on the pleadings in favor            
          of respondent.  Our opinion disposing of respondent’s motion,               
          Harrell v. Commissioner, T.C. Memo. 1996-64, closed with the                
          following paragraph.                                                        
                    We would ordinarily caution petitioner that his                   
               continuing advancement of frivolous and groundless protester           
               allegations might subject him to a penalty under the                   
               provisions of section 6673.  Petitioner, however, has                  
               already received and ignored such a warning.  Petitioner is            

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