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1. Whether respondent’s determination of petitioner’s
income tax deficiencies for 2000 and 2001 is valid. We hold that
it is.
2. Whether petitioner was denied equal protection and due
process of law because respondent failed to allow business
expense deductions based on statistical information. We hold
that he was not.
3. Whether petitioner is liable for additions to tax for
failure to file under section 6651(a) and for failure to pay
estimated tax under section 6654(a). We hold that he is.
4. Whether petitioner is liable for a penalty under
section 6673 for instituting proceedings primarily for delay and
for maintaining frivolous or groundless positions. We hold that
he is not.
Section references are to the Internal Revenue Code.
FINDINGS OF FACT
The parties submitted this case fully stipulated under Rule
122.
A. Petitioner
Petitioner lived in Ormond Beach, Florida, when he filed his
petition. In 2000 and 2001, petitioner sold insurance and
financial products for which he received commissions. He
received the following payments:
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Last modified: May 25, 2011