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As explained in detail below, there is no genuine issue as
to any material fact, and a decision may be rendered as a matter
of law. Accordingly, we shall grant respondent’s motion for
summary judgment.
Background
The record establishes and/or the parties do not dispute the
following.
A. Petitioner’s Failure To File
Petitioner has a history of failing to file Federal income
tax returns. Specifically, petitioner failed to file Federal
income tax returns for 1990 through 1993, the four taxable years
in issue. The record suggests that petitioner also failed to
file Federal income tax returns for 1994 through 1999.
B. Respondent’s Notices of Deficiency
On May 17, 1994, respondent issued a notice of deficiency to
petitioner for 1990. In the notice, respondent determined a
deficiency in petitioner’s Federal income tax in the amount of
$3,121, an addition to tax under section 6651(a)(1) in the amount
of $585 for failure to file a tax return, and an addition to tax
under section 6654(a) in the amount of $148 for failure to pay
estimated tax. The deficiency in income tax was based on
respondent’s determination that petitioner failed to report
wages, unemployment compensation, and interest income as reported
to respondent by various third-party payors.
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