- 2 -
After concessions by the parties, the issues for decision
are: (1) Whether, for income tax purposes, petitioner, who
specifically bargained to be paid in American Eagle gold coins
(the gold coins) for timber he sold during the taxable years in
issue must report his income at the coins' face value or at their
higher fair market value. We hold petitioner must report the
coins at their fair market value, to the extent set out below.
(2) Whether petitioner is liable for additions to tax under
section 6651(a)(1)1 for failure to timely file Federal income tax
returns for 1992, 1993, and 1994. We hold he is, to the extent
set out below.2
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
1 All section references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, unless otherwise
indicated.
2 Although in written documents filed with the Court
petitioner raised various arguments, such as that the income tax
is really an excise tax and does not apply to him, that he is a
citizen of Oregon and not of the United States, that he is not
subject to "maritime jurisdiction", that the OMB number on Form
1040 is incorrect, and similar irrelevant or erroneous
contentions, he renounced those arguments after having been
warned by the Court that he was putting himself in jeopardy of a
penalty under sec. 6673. We do not consider those contentions
worthy of further discussion, nor will we dignify petitioner's
arguments by addressing them one by one. See Crain v.
Commissioner, 737 F.2d 1417 (5th Cir. 1984); see also Sherwood v.
Commissioner, T.C. Memo. 1997-26; Barcroft v. Commissioner, T.C.
Memo. 1997-5.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011