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OPINION
I. Contentions of the Parties
Petitioner contends that he is not required to file a
Federal income tax return for 2000. Specifically, he asserts
that he did not generate a sufficient amount of income to require
him to file a return. Petitioner further argues that since he
did not have an income tax liability for the previous tax year,
he is not required to file estimated taxes. In addition,
petitioner has a history of espousing tax protester arguments in
opposition to the filing requirement of section 6011.
Respondent claims that petitioner earned income in the form
of wages, interest, and capital gain for 2000. Since petitioner
did not appear at trial, nor did he or his counsel provide any
evidence or documentation to the contrary, respondent contends
that the determination of petitioner’s tax liability and
additions to tax are correct.
II. Petitioner’s Income Tax Liability
A. General Rules
In general, the Commissioner’s determination of a taxpayer’s
tax liability is presumed correct, and the taxpayer bears the
burden of proving that respondent’s determination is improper.
5(...continued)
accompanied by the affidavit of a legal assistant employed by
Unisys, who certified that they were true and correct copies of
the originals.
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