T.C. Memo. 2005-216
UNITED STATES TAX COURT
JOSEPH JOHN MARTELLA, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7504-04. Filed September 19, 2005.
P failed to file Federal income tax returns for
the 1998 and 2001 years. R determined deficiencies and
additions to tax, which P contested primarily on the
basis of inapplicability of the filing requirement and
tax protester arguments.
Held: P is liable for deficiencies in his income
taxes and additions to tax under secs. 6651(a)(1) and
6654, I.R.C., for 1998 and 2001.
Joseph John Martella, pro se.
Fred E. Green, Jr., for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: For petitioner’s 1998 taxable year,
respondent determined a Federal income tax deficiency in the
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