Lance Standifird - Page 2




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          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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