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1. Whether petitioner had a capital gain of $71,001 on the
sale of his personal residence in 1994. We hold that he did.
2. Whether petitioner had unreported dividend income of
$796 from Kemper Clearing Corp. in 1994. We hold that he did.
3. Whether petitioner is liable for an addition to tax
under section 6651(a)(1) for failure to file a timely income tax
return for 1994. We hold that he is.
4. Whether petitioner is the taxpayer named in the notice
of deficiency. We hold that he is.
5. Whether petitioner's constitutional arguments have
merit. We hold that they do not.
Section references are to the Internal Revenue Code in
effect during the year in issue. Unless otherwise indicated,
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
A. Petitioner
Petitioner lived in Arizona when he filed the petition and
amended petition in this case.
1. Sale of Petitioner's Residence
Petitioner and Barbara A. Ploe (Ploe) bought 4 acres of land
at 3545 Sierra Lane in Yavapai County, Arizona, the deed for
which was recorded on January 31, 1985. He and Ploe were not
married at that time. Petitioner personally built a 4,000
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