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liability for the additions to tax under section 6651(a)(1).
Moreover, as discussed, respondent previously had properly
applied the overpayment to petitioner’s 1989 and 1990 tax
liabilities and refunded the remainder to him.
In closing, we note that petitioner is an attorney and has a
history of not timely filing tax returns and of apparently
ignoring any communications from respondent, including not
opening envelopes with refund checks. This is the crux of the
dispute before the Court. Under these circumstances,
petitioner’s claim that he is an abused taxpayer has a decidedly
hollow ring.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011