- 2 - 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 arePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011