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In two notices of deficiency, respondent determined
deficiencies in petitioner’s Federal income taxes of $21,799,
$27,016, $17,327, $25,967, and $20,709, for the taxable years
1994, 1995, 1996, 1997, and 1998, respectively. Respondent
determined additions to tax under section 6651(a)(1) in the
amounts of $1,089.95, $1,350.80, $866.35, $6,491.75, and
$5,177.25 and additions to tax under section 6654 in the amounts
of $1,131.20, $1,313.33, $922.24, $1,389.28, and $947.60 for
1994, 1995, 1996, 1997, and 1998, respectively. The issues for
decision are: (1) Whether petitioner had unreported income as
determined by respondent; (2) whether petitioner failed to file
Federal income tax returns without reasonable cause; and (3)
whether petitioner underpaid estimated income taxes.
At the time the petitions were filed, petitioner resided in
Fort Worth, Texas.
Background
Petitioner filed petitions in which he alleged that "I
dispute all of the above [tax deficiencies and additions to tax]
due to the fact that I am not required to file a tax return for a
variety of reasons." Respondent filed in each case a motion to
dismiss for failure to state a claim upon which relief can be
granted.
In consideration of respondent's motions, the Court ordered
petitioner to file proper amended petitions setting forth clear
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Last modified: May 25, 2011