- 2 -
appropriate. In his petition, petitioner requests us to
determine whether respondent improperly refused to abate
assessments for additions to tax under section 6651(a)(1) and (2)
and section 6654, and interest on those additions to tax,2
arising from delinquent income tax returns filed by petitioner
for 1996-99.
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 in this case was filed, petitioner
resided in Clearwater, Florida.
Petitioner graduated from Stetson University in Deland,
Florida, where he received a bachelor of science degree in
physics. After graduating from college, petitioner served in the
military, and, after a 3-year tour of duty with the Signal Corps,
he attended and graduated from law school. Petitioner returned
to the military and practiced criminal law in the U.S. Army at
Fort Ord, California. He later worked as an attorney for the
Department of Energy, where he practiced patent law.
In 1985, petitioner moved to Clearwater, Florida, where he
has been practicing law as a sole practitioner. The bulk of his
2Petitioner has conceded that he is liable for interest on
additions to tax under secs. 6651(a)(1) and (2) and 6654 if such
additions are not abated.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011