-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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Last modified: May 25, 2011