- 2 - 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 duePage: Previous 1 2 3 4 Next
Last modified: May 25, 2011