- 4 - not subject to taxation and therefore not liable for income taxes is without merit. The short answer to petitioner's assertions is that he is not exempt from Federal income tax. See Abrams v. Commissioner, 82 T.C. 403, 406-407 (1984). Petitioner's arguments are wholly frivolous and have been repeatedly rejected by this Court as well as the Court of Appeals for the Fifth Circuit, the circuit to which an appeal would lie in this case. See, e.g., United States v. Price, 798 F.2d 111 (5th Cir. 1986); Anderson v. United States, 754 F.2d 1270 (5th Cir. 1985); Lonsdale v. Commissioner, 661 F.2d 71 (5th Cir. 1981), affg. per curiam T.C. Memo. 1981-122; Abrams v. Commissioner, supra; Rowlee v. Commissioner, 80 T.C. 1111 (1983); Sochia v. Commissioner, T.C. Memo. 1995-475, affd. without published opinion 116 F.3d 478 (5th Cir. 1997). Accordingly, we hold that petitioner is liable for the deficiency in tax as determined by respondent. Section 6651(a) imposes an addition to tax for a taxpayer's failure to file a required return on or before the specified filing date, including extensions. The addition to tax is inapplicable, however, if the taxpayer shows that the failure to file the return was due to reasonable cause and not to willful neglect. See sec. 6651(a)(1). It is undisputed that petitioner failed to file a Federal income tax return for the year 1995. Furthermore, petitioner has not provided this Court with anyPage: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011