- 4 - OPINION On brief petitioner argues that: (1) Respondent has no jurisdiction over him in this matter, and therefore, the notice of deficiency is void; (2) this Court lacks subject matter jurisdiction; and (3) petitioner is not a “person” or “individual” as those terms are defined and applied in title 26. Petitioner’s arguments are reminiscent of tax-protester rhetoric that has been universally rejected by this and other courts. We shall not painstakingly address petitioner's assertions "with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit." Williams v. Commissioner, 114 T.C. , (2000) (slip op. at 5) (quoting Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984)). Accordingly, we hold that petitioner is liable for the deficiency determined by respondent. Respondent determined that petitioner is liable for an addition to tax pursuant to section 6651(a)(1). Section 6651(a)(1) provides an addition to tax for failure to timely file a return. The addition to tax is equal to 5 percent of the amount required to be shown as tax on the return, with an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate. A taxpayer may avoid the addition to tax by establishing that the failure to file a timely return wasPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011