- 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 any
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011