T.C. Memo. 2000-26
UNITED STATES TAX COURT
RUSSELL S. GREENE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15225-98. Filed January 21, 2000.
P, maintaining that income tax could not
constitutionally be imposed on his earnings, did not file
income tax returns for the taxable years 1992 through 1996.
R determined deficiencies for individual income taxes and
self-employment taxes attributable to compensation,
interest, dividends, and capital gain received by P. R
further determined an addition to tax under sec. 6651(a),
I.R.C., for failure to file.
Held: P is subject to Federal income tax statutes and
is liable for the deficiencies determined by R.
Held, further, P is liable for the sec. 6651(a),
I.R.C., delinquency addition to tax for failure to file.
Held, further, on the Court’s own motion, P is liable
for a penalty in the amount of $1,000, pursuant to sec.
6673(a), I.R.C., for asserting a frivolous and groundless
position in this proceeding.
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