- 4 - respondent, with an attachment in which he raised numerous frivolous contentions, such as he was not a taxpayer, he had engaged in no taxable activity, and respondent had not prepared proper substitute for returns. Petitioner asked respondent to show him the statute that made him liable for Federal income tax. C. Notice of Deficiency Respondent sent and petitioner received a notice of deficiency for 1994-99 dated September 12, 2001. In it, respondent determined, based on information that respondent obtained from petitioner’s clients and banks, that petitioner had the following amounts of unreported income from Diversified Accounting Services: Year Income 1994 $34,067 1995 27,848 1996 30,639 1997 35,579 1998 30,772 1999 43,284 Respondent determined that petitioner had income tax deficiencies and liability for additions to tax as follows: Additions to tax Year Deficiencies Sec. 6651(f) Sec. 6654(a) 1994 $4,834 $3,625.50 $250.84 1995 3,214 2,410.50 174.26 1996 3,621 2,625.22 192.71 1997 4,853 3,518.42 259.63 1998 3,574 2,591.15 163.53 1999 6,796 4,927.10 328.88 Respondent also determined that petitioner was liable for the addition to tax for failure to pay under section 6651(a)(2) inPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011