- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011