Douglas J. Crawford - Page 2

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          timely Federal income tax returns pursuant to section 6651(a)(1)1           
          as follows:                                                                 
          Additions to Tax                                                            
                    Year      Deficiency     Sec. 6651(a)(1)                          
                    1991      $3,074         $106.50                                  
                    1993      2,156          539.00                                   
               Following concessions by respondent,2 the issues for                   
          decision are:  (1) Whether the Tax Court has jurisdiction to                
          consider petitioner's constitutional objections; (2) whether                
          assignment of a case to a Special Trial Judge pursuant to section           
          7443A(b)(3) violates petitioner's constitutional rights; (3)                
          whether unemployment compensation received by petitioner in 1991            
          should be included in petitioner's 1991 gross income; (4) whether           
          petitioner is liable for an addition to tax pursuant to section             
          6651 for failing to file a Federal income tax return for 1991;              
          and (5) whether petitioner is liable for a penalty under section            
               The evidence in this case consists of a stipulation of facts           
          with the attached exhibits (incorporated herein by reference) and           

          1    All section references are to the Internal Revenue Code in             
          effect for the tax years in issue, unless otherwise indicated.              
          All Rule references are to the Tax Court Rules of Practice and              
          2    Respondent has conceded that petitioner is not liable for              
          any deficiency in income tax or addition to tax for the taxable             
          year 1993.  Respondent also conceded that petitioner used the               
          standard deduction in computing his 1990 Federal income tax and             
          that petitioner's refund of State income taxes is not includable            
          in petitioner's 1991 income.                                                

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