- 4 -
06/30/00 Qwest Communications Intl. 46
02/01/00 SBC Communications Inc. 8,637
02/03/00 SBC Communications Inc. 46
02/03/00 SBC Communications Inc. 46
02/04/00 SBC Communications Inc. 44,594
02/04/00 U.S. West Inc. 5,011
Petitioner also received ordinary dividends and capital
gains in the amounts of $13,572 and $11,378, respectively.
OPINION
I. Introduction
We first address petitioner’s constitutional challenge to
the income tax. We then determine petitioner’s gain from the
sale of the securities. Finally, we address the additions to tax
and section 6673 penalty.
II. Petitioner’s Constitutional Challenge to the Income Tax
In the amended petition, in support of his assignments of
error, petitioner claims that he has books and records
substantiating his deductions, business expenses, credits, and
charitable contributions. At the trial of this case, petitioner
conceded that, during 2000, the sale of the securities produced
proceeds of $225,390 and he received ordinary dividends and
capital gains in the amounts of $13,572 and $11,378,
respectively. He offered nothing to show any business expenses,
credits, or charitable contributions. He conceded that he did
not file a tax return for 2000. His wife, apparently speaking
for him, claimed that, even if the Court were to find that he had
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011