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The issues for decision are:
1. Whether petitioner may dispute the existence or amount
of his tax liability for 1994-99. We hold that he may not.
2. Whether respondent’s determination was an abuse of
discretion. We hold that it was not.
3. 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.
Section references are to the Internal Revenue Code.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioner
Petitioner lived in Daytona Beach, Florida, when he filed
the petition. In 1994-99, petitioner was a professional income
tax return preparer who did business through an S corporation
called Diversified Accounting Services. Petitioner was its sole
officer and shareholder. Petitioner filed no Federal income tax
returns for 1994-99.
B. Respondent’s Examination of Petitioner’s 1994-99 Tax Years
Respondent’s revenue agent notified petitioner that he had
not filed Federal income tax returns for 1994-99 and asked for
information to determine his tax liability for those years.
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Last modified: May 25, 2011