Ronald Lee Snyder - Page 4

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          tute for return for that taxable year.                                      
               On or about September 7, 2000, petitioner filed a tax return           
          for his taxable year 1999 (1999 return).  In his 1999 return,               
          petitioner reported taxable income of $0 and tax of $0.  Peti-              
          tioner remitted a $3 payment with that return.                              
               On October 9, 2001, respondent issued to petitioner a notice           
          of deficiency with respect to his taxable years 1998 and 1999,              
          which he received.  In that notice, respondent determined defi-             
          ciencies in, additions to, and an accuracy-related penalty on               
          petitioner’s tax, as follows:                                               
                              Additions to Tax           Accuracy-Related Penalty     
          Year Deficiency Sec. 6651(a)(1)     Sec. 6654(a)        Sec. 6662(a)        
          1998   $8,080      $423.50        $45.03              --                    
          1999   11,766      687.25           --              $549.80                 
               Petitioner did not file a petition with the Court with                 
          respect to the notice of deficiency relating to his taxable years           
          1998 and 1999.  Instead, on December 17, 2001, in response to               
          that notice, petitioner sent a letter to Charles O. Rossotti, who           
          was at the time the Commissioner of the Internal Revenue.  That             
          letter stated in pertinent part:                                            
               As the new Commissioner of Internal Revenue and one who                
               is not a lawyer, you might still be shocked to discover                
               that the payment of income tax is totally voluntary,                   
               and not mandatory - as you were probably misled to                     
               believe while employed in the private sector.  If you                  
               don’t believe me, ask your legal counsel to show you a                 
               Code Section that established a “liability” for income                 
               taxes and a requirement “to pay” such a tax * * *.                     
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