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The issues for decision1 are:
1. Whether petitioner had gross income and deductions in
the amounts respondent determined for 1998, 2000, and 2001. We
hold he did.
2. Whether petitioner is liable for the addition to tax
for failure to timely file under section 6651(a)(1)2 for 1998,
and for the accuracy-related penalty under section 6662(a) for
1998, 2000, and 2001. We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
1 We ordered the parties to file posttrial briefs.
Respondent did so; petitioner did not. Under these
circumstances, we may hold petitioner in default on all issues
for which he bears the burden of proof. See Stringer v.
Commissioner, 84 T.C. 693, 704-708 (1985), affd. without
published opinion 789 F.2d 917 (4th Cir. 1986); Furniss v.
Commissioner, T.C. Memo. 2001-137; McGee v. Commissioner, T.C.
Memo. 2000-308. However, we decide this case on the record as it
stands. We base our understanding of petitioner’s position on
his petition and trial testimony.
2 Section references are to the Internal Revenue Code as
amended and in effect for the years in issue.
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