Glenn S. Hodges - Page 2

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                    4.  Held, further, P is liable for an addition to                 
               tax under sec. 6654, I.R.C., for failure to pay                        
               estimated tax.                                                         
                    5.  Held, further, P is penalized $15,000 under                   
               sec. 6673(a)(1), I.R.C., because his position in this                  
               proceeding is frivolous.                                               

               Glenn S. Hodges, pro se.                                               
               John W. Sheffield III, for respondent.                                 


                      MEMORANDUM FINDINGS OF FACT AND OPINION                         

               HALPERN, Judge:  By notice of deficiency dated March 4,                
          2003, respondent determined a deficiency in petitioner’s 2000               
          Federal income tax of $84,014 and additions to tax of $18,903,              
          $7,561, and $4,519, under sections 6651(a)(1) and (2) and                   
          6654(a), respectively.  Petitioner assigns error to all of those            
          determinations.  By the answer, respondent concedes the addition            
          to tax determined under section 6651(a)(2) and claims an increase           
          in the addition to tax determined under section 6651(a)(1) of               
          $2,100 (for a total addition under that section of $21,003).                
          Taking into account certain concessions made by petitioner, the             
          issues remaining for decision are (1) petitioner’s constitutional           
          challenge to the income tax, (2) petitioner’s gain, if any, from            
          certain sales of securities, (3) the additions to tax, and (4)              
          our imposition of a penalty upon petitioner under section 6673.             







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