T.C. Memo. 2002-41 UNITED STATES TAX COURT ANDREW HEISEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1220-01. Filed February 12, 2002. P did not file Federal income tax returns for 1996, 1997, and 1998. R issued a notice of deficiency for those years, in which he determined deficiencies, as well as additions to tax under secs. 6651(a)(1) and (2) and 6654, I.R.C. P does not dispute the receipt of compensation and sale proceeds in the amounts determined by respondent. However, P contends that the Federal income tax is in the nature of an excise tax and that he is not engaged in any taxable excise activities. Held: Compensation and gain from the sale of property are taxable as income in the year received. P’s arguments to the contrary are frivolous. Held, further, the additions to tax under secs. 6651(a)(1) and 6654, I.R.C., are sustained. Held, further, sec. 6651(a)(2), I.R.C., provides an addition to tax where a taxpayer fails “to pay the amount shown as tax on any return”. The addition toPage: 1 2 3 4 5 6 7 8 Next
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