- 4 - determined that petitioner's proper filing status for income tax purposes for each year before the Court was single. Accordingly, respondent calculated the deficiencies and additions to tax using the tax rates applicable to unmarried individuals pursuant to section 1(c). OPINION Petitioner does not challenge the facts on which respondent’s determinations are based.1 Petitioner’s sole claim in this case is that he should be accorded married, rather than single, filing status on his tax returns for the years 1989 to 1995. Petitioner does not claim to have ever been married. Rather, petitioner argues that he had an "economic partnership" with his roommate and that he was unconstitutionally denied the opportunity to file a joint tax return with him in recognition of such partnership. Petitioner references a number of constitutional provisions, but we understand the crux of petitioner’s constitutional claim to be that the tax code’s unequal or differential treatment between married taxpayers and unmarried persons in an economic partnership constitutes a violation of the due process notions implicit in the Fifth 1At trial petitioner alleged for the first time that he had suffered several theft losses during the years at issue. However, petitioner failed to substantiate any such losses and abandoned the argument on brief.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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