- 9 - Court, as well as other courts, and have been consistently rejected. The Court sees no need to further respond to each of petitioner's arguments with somber reasoning and copious citations of precedent, to do so might suggest that petitioner's arguments possess some measure of colorable merit. See Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984). In short, petitioner is a taxpayer subject to the income tax laws and to the jurisdiction of this Court. See Abrams v. Commissioner, 82 T.C. 403, 406-407 (1984). On this record, the Court holds that petitioner is liable for Federal income taxes on income of $2,040.63 for 1992, and income of $21,909 for 1994, as determined by respondent in the notices of deficiency. Respondent is, therefore, sustained on this issue. The second issue is whether petitioner is liable for the addition to tax under section 6651(a)(1) for his failure to file timely a Federal income tax return for 1994. Section 6651(a)(1) imposes an addition to tax for a taxpayer's failure to file timely returns, unless the taxpayer can establish that such failure "is due to reasonable cause and not due to willful neglect." Petitioner's 1994 income tax return was due to be filed on or before April 15, 1995. Petitioner failed to file a valid return for 1994. Sloan v. Commissioner, 102 T.C. 137 (1994), affd. 53 F.3d 799 (7th Cir. 1995); see supra note 5.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011