- 5 -
Taxable Years 1993, 1994, and 1995
On October 24, 2000, the Court entered a decision at docket
No. 18627-97 sustaining deficiencies and additions to tax
(including additions to tax under section 6651(a)(1) for failure
to file a tax return) that respondent determined against
petitioner for the taxable years 1993, 1994, and 1995. The
Court's decision included an increased deficiency for 1993.4 The
Court also imposed a penalty upon petitioner pursuant to section
6673(a) after concluding that petitioner "knowingly and
repeatedly advocated frivolous and groundless positions." Howard
v. Commissioner, T.C. Memo. 2000-222.
Taxable Year 1996
On April 5, 2002, the Court entered a decision at docket No.
6546-00 sustaining the deficiency and additions to tax that
respondent determined against petitioner for the taxable year
1996. Citing the Court's two earlier Memorandum Opinions
(referred to above) and characterizing petitioner’s arguments as
“frivolous and wholly without merit”, the Court imposed a penalty
4 In Howard v. Commissioner, T.C. Memo. 2000-222, we held
that a tax return that petitioner had submitted to respondent for
1993 was invalid because it was not properly executed. Although
respondent conceded that he improperly entered an assessment of
$2,696 against petitioner based upon such return, respondent
proved at trial that petitioner was liable for a total deficiency
of $5,832, including the $2,696 amount, and a total sec.
6651(a)(1) addition to tax of $1,458.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011