Daniel J. Sides - Page 2

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               After concessions, the sole issue for decision is whether to           
          impose a penalty pursuant to section 6673.                                  
          Background                                                                  
               Petitioner is 26 years old.  In the petition, petitioner               
          made tax protester type arguments.                                          
               At calendar call, petitioner appeared and admitted that he             
          received income as determined in the notice of deficiency.                  
          Petitioner stated that he realized that the arguments he made in            
          the petition were inappropriate.  Petitioner conceded that he               
          owed the deficiency and the section 6662 penalty.                           
               Petitioner admitted that respondent previously assessed the            
          section 6702 frivolous return penalty against him.  Petitioner              
          stated that this was the first time he pursued these arguments in           
          administrative or legal proceedings.  Petitioner further stated             
          that he did not intend to make these arguments in the future, he            
          understood he owed taxes on income he earned and income taxes are           
          constitutional, and he does not intend to appear in the Court               
          again.                                                                      
               Petitioner indicated his willingness to sign a document                
          attesting to his concessions.  Petitioner promptly signed a                 
          document (stipulation of settlement) that was filed with the                
          Court at the hearing on the section 6673 penalty.  In the                   
          stipulation of settlement, petitioner agreed that there was a               
          deficiency of $2,987 and a section 6662 penalty of $327.40 due              






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