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petitioner should be required to pay a penalty to the United
States pursuant to section 6673 for instituting and/or
maintaining this proceeding, and if so the amount thereof.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the exhibits submitted therewith are
incorporated herein by this reference.
At the time the petition was filed, petitioner resided in
Ocala, Florida. He is a doctor of veterinary medicine.
Petitioner timely filed income tax returns for 1996 and
1997. On the 1996 tax return, the amount of tax due (exclusive
of the estimated tax penalty) was shown as $17,112. There were
no withholding credits or estimated tax payments. Nor was there
a payment submitted with the return.
The tax shown as due (exclusive of the estimated tax
penalty) on the 1997 return was $13,734. Other than one
estimated tax payment of $1,100, petitioner made no payments with
respect to his 1997 tax liability.
On February 13, 2001, petitioner filed amended income tax
returns on Forms 1040X, Amended Individual Income Tax Return, for
1996 and 1997. These returns, as well as amended returns for
1998 and 1999, were submitted “as a part” of petitioner’s 2000
income tax return. The amended returns reported that petitioner
1All section references are to the Internal Revenue Code.
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