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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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Last modified: May 25, 2011