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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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