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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) in
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