T.C. Memo. 2003-333
UNITED STATES TAX COURT
JOHN R. TONEY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10683-01. Filed December 4, 2003.
P reported taxable income of “zero” on his 1986
tax return, claiming he was not liable for tax due as
no section of the Internal Revenue Code imposed a tax
upon him. P was charged with, and subsequently pleaded
guilty to, one count of criminal tax evasion for 1986
in violation of 26 U.S.C. sec. 7201 (2000).
R determined a deficiency of $14,611, additions to
tax for fraud pursuant to sec. 6653(b), I.R.C., and an
addition to tax for substantial understatement pursuant
to sec. 6661, I.R.C. On Feb. 10, 2003, R moved for
summary judgment.
Held: R’s motion for summary judgment is granted
in full.
Held, further, P is liable for a deficiency in the
amount of $14,611 for 1986 based on his deemed
admission.
Held, further, P is liable for the additions to
tax for fraud pursuant to sec. 6653(b), I.R.C. Based
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011