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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 is
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