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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
6673(a).
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
Procedure.
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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Last modified: May 25, 2011