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Additions to Tax and Penalties
Year Deficiency Sec. 6651(f) Sec. 6653(b)(1)(A) Sec. 6654
1987 $59,607 -0- $44,705.79 $3,199.79
1988 57,101 -0- 42,825.75 3,672.94
1989 70,534 $52,900.50 -0- 4,770.17
1990 68,450 51,337.50 -0- 4,481.53
1991 74,079 55,559.25 -0- 4,233.69
1992 88,708 66,531.00 -0- 3,869.04
1993 69,563 52,172.25 -0- 2,914.65
Respondent also determined an addition to tax under section
6653(b)(1)(B) for 1987. Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Throughout these proceedings, petitioner has maintained only
frivolous positions. To the extent that his voluminous
submissions are intelligible, he contends that he is not a
taxpayer, that his income from sale of hospital supplies is not
an item of income taxable under section 61, and that the
regulations promulgated under section 61 provide that only
foreign income is taxable. Petitioner has maintained these
positions despite having been convicted of tax evasion under
section 7201 for 1990, 1991, 1992, and 1993 and of conspiracy to
obstruct and impede the Internal Revenue Service (IRS) under 18
U.S.C. sec. 371.
Petitioner failed to present any evidence that the amounts
of income and deductions determined in the statutory notice are
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