-4- public accountant about petitioner’s duty to file a tax return for 1993. Petitioner’s failure to file tax returns since 1979 is intentional. 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 isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011