-2- 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 4,000Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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