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claim to exemption. Petitioner, in his response, also complains
that respondent has failed to explain the grounds for
respondent's determination and has failed to identify for
petitioner's benefit the treaties or statutes that might entitle
him, independently of the provisions of the U.S. Constitution, to
exemption from Federal income tax. However, petitioner has not
pleaded or otherwise identified to respondent or the Court any
facts regarding petitioner's status as a member of any Indian
nation or tribe that might entitle him to exemption from Federal
income tax under any statute or treaty.
In his response to respondent's motion, petitioner also
asserts--for the first time--that if he should be mistaken in his
claim to exemption from Federal income tax, he is entitled to
itemized deductions for charitable contributions and payments of
home mortgage interest, which would substantially reduce his tax
liabilities, that he had and continues to have reasonable cause
for not filing tax returns, and that additions for failure to pay
estimated tax should not be imposed.
Discussion
Respondent's motion will be granted in part, insofar as we
sustain respondent's determinations that petitioner is not exempt
from Federal income tax and that petitioner is liable for
estimated tax additions on any deficiencies that we may
ultimately redetermine.
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Last modified: May 25, 2011