-2-
of approximately $20,728 for 1990 and $30,737.52 for 1991.1
Currently, the case is before the Court on respondent’s motion
for summary judgment under Rule 121 and to impose a penalty under
section 6673. Petitioner responded to respondent’s motion under
Rule 121(b).
We shall grant respondent’s motion for summary judgment and
shall impose a $7,500 penalty against petitioner. In addition,
we dismiss for lack of jurisdiction the part of the petition with
respect to the frivolous return penalties and related interest.
Unless otherwise noted, section references are to the applicable
versions of the Internal Revenue Code. Rule references are to
the Tax Court Rules of Practice and Procedure.
Background
On October 15, 1992, petitioner filed a 1990 U.S.
nonresident alien income tax return in which he reported zero
taxable income. Petitioner reported that he was not a U.S.
citizen and had not visited the U.S. in 1990. Petitioner stated
that his country of residence was “America.”
On September 22, 1995, respondent issued to petitioner a
notice of deficiency for 1990. The notice determined that
petitioner was liable for an $11,224 deficiency in his 1990
income tax and a $2,806 addition to tax under section 6651(a)(1)
1 We use the term “approximately” because these amounts were
computed before the present proceeding and have since increased
on account of interest.
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