Alan D. Stang - Page 3

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               (3) whether petitioner is liable for the section 6651(a)(1)            
          addition to tax for failure timely to file income tax returns for           
          the taxable years 1999 through 2001;                                        
               (4) whether petitioner is liable for the section 6654                  
          addition to tax for 1999, 2000, and 2001 on account of failure to           
          pay estimated income taxes; and                                             
               (5) whether the Court should impose a penalty under section            
          6673.                                                                       
                                  FINDINGS OF FACT                                    
               Some of the facts have been deemed stipulated pursuant to              
          Rule 91(f).  The deemed stipulations, with accompanying exhibits,           
          are incorporated herein by this reference.  At the time the                 
          petition was filed in these cases, petitioner resided in Arizona.           
               Petitioner was hired by GCE, a firm providing engineering              
          services, with a starting date of January 8, 1996.  Petitioner              
          had a background in electronics and was employed as a field                 
          service technician.  In conjunction with his employment,                    
          petitioner on January 4, 1996, signed a Form W-4, Employee’s                
          Withholding Allowance Certificate, claiming he was exempt from              
          Federal income tax withholding requirements.                                
               Respondent’s administrative file further reflects that                 
          petitioner subsequently, in January of 1997, executed a statement           
          asserting that he was a sovereign citizen of Arizona; a Form W-8,           
          Certificate of Foreign Status; another Form W-4 claiming                    






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