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Stephen W. Williams, pro se.
M. Kathryn Bellis and Marion S. Friedman, for respondent.
OPINION
VASQUEZ, Judge: Respondent determined a deficiency of
$42,934, an addition to tax pursuant to section 6651(a)(1) of
$9,492, and an accuracy-related penalty pursuant to section
6662(a) of $8,587 in petitioner’s 1991 Federal income tax.1
Pursuant to Rule 122, the parties submitted this case fully
stipulated. The stipulations of fact, the supplemental
stipulations of fact, and the attached exhibits are incorporated
herein by this reference. At the time the petition was filed,
petitioner resided in Spring, Texas.
After concessions,2 the issues for decision are: (1)
Whether petitioner is liable for the deficiency determined by
respondent in petitioner’s 1991 taxes; (2) whether petitioner’s
Form 1040, U.S. Individual Income Tax Return, containing a
disclaimer statement constituted a valid return, and if so,
whether petitioner is liable for a penalty pursuant to section
6662; (3) whether petitioner is liable for an addition to tax
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for 1991, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
2 Respondent concedes that petitioner is entitled to a head
of household filing status and a dependency exemption deduction
for his son, Steve W. Williams.
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Last modified: May 25, 2011