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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.
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Last modified: May 25, 2011