Anthony P. Hart - Page 3




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          Form W-2, petitioner submitted a Form 4852, Substitute Form W-2,            
          requesting a Form W-2 correction to indicate that he received no            
          “wages, tips or other compensation.”  Throughout this course of             
          events, petitioner knew that the Form W-2 statement was entirely            
          accurate.                                                                   
               Petitioner also filed an unsigned Form 1040, U.S. Individual           
          Income Tax Return, indicating that he had no income, and no tax             
          liability.  Apparently, the Internal Revenue Service Center                 
          treated the unsigned Form 1040 as if it were a valid return, and            
          thus failed to determine a 25-percent addition to tax under                 
          section 6651(a) for petitioner’s failure to file a timely tax               
          return.  Instead, respondent determined in the notice of                    
          deficiency that petitioner was liable for a 20-percent accuracy-            
          related penalty under section 6662(a).  Also in the notice,                 
          respondent determined an addition for failure to pay estimated              
          taxes under section 6654(a).                                                
               In his petition, petitioner states that he is not a tax                
          protester.  He says our tax laws are very clearly written, and              
          provide that he need not pay tax on his income because he was not           
          engaged in an “excise taxable activity” for the tax period in               
          question.                                                                   
               On March 5, 2001, in compliance with the Court’s pretrial              
          order, petitioner filed a trial memorandum that we are treating             
          as his brief.  Petitioner argues in his brief that he owes no               






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