Carol J. Jarboe - Page 2




                                         -2-                                          
                                        Additions to Tax                              
          Year      Deficiency          Sec. 6651(a)(1)     Sec. 6654                 
          1991      $7,788              $1,290              $280                      
          1992      7,449                    1,148          188                       
          1995      13,359                   3,340          726                       
          1996      13,625                   3,406          731                       
          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.                                      
               In a petition filed July 10, 1998, Ms. Jarboe, then a                  
          resident of Marion, Pennsylvania, contested all of respondent's             
          determinations.  After concessions, the sole issue is whether the           
          income tax laws are constitutional.                                         
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  Ms. Jarboe, a self-employed practical nurse, received            
          $42,480 and $43,481 of nonemployee compensation from Absolute               
          Nursing Care, Inc., in 1995 and 1996, respectively.  Ms. Jarboe             
          also received $1,540 and $1,587 of taxable distributions from               
          Principal Mutual Life Insurance Co. in 1995 and 1996,                       
          respectively.  In 1995, Ms. Jarboe received $20 of taxable                  
          interest from Blue Ridge Bank.  Ms. Jarboe did not file Federal             
          income tax returns, and did not pay estimated taxes, relating to            
          1995 and 1996.                                                              
               Ms. Jarboe admits that she received compensation from                  
          Absolute Nursing Care, Inc., distributions from Principal Mutual            
          Life Insurance Co., and interest from Blue Ridge Bank, but                  
          contends that the tax laws are unconstitutional.  Her contention            





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