Russell S. Greene - Page 1

                                   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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