- 4 - pertaining to unmarried (single) individuals and allowed petitioner one personal exemption and the applicable standard deduction. The additions to tax under section 6651(a)(1) are based on respondent's determination that petitioner's failure to file for 1996 and 1997 was not due to reasonable cause. The additions to tax under section 6651(a)(2) are based on respondent’s determination that petitioner’s failure to pay his tax liability for 1996 and 1997 was not due to reasonable cause. Finally, the additions to tax under section 6654(a) are based on respondent's determination that petitioner failed to pay the requisite amount of estimated taxes for 1996 and 1997. On June 8, 2000, petitioner timely filed a petition for redetermination. See sec. 6213(a). Discussion At trial, petitioner stated that he did not dispute any of the income amounts determined by respondent in the notice of deficiency.2 Rather, petitioner took the position that “The income items are irrelevant.” In addition, petitioner alleged that the Government has shown him nothing that “connects me with 2 Indeed, in the petition, petitioner did not set forth any assignments of error nor any statements of fact. See Rule 34(b)(4) (“Any issue not raised in the assignments of error shall be deemed to be conceded.”); see also Rule 34(b)(5); cf. Parker v. Commissioner, 117 F.3d 785 (5th Cir. 1997); White v. Commissioner, T.C. Memo. 1997-459.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011