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Respondent determined a deficiency of $10,286 in
petitioners’ 2001 Federal income tax and a section 6662(a)1
penalty of $2,057.20. The issues for decision are: (1) Whether
petitioners are liable for the deficiency determined by
respondent; (2) whether petitioners are liable for an accuracy-
related penalty pursuant to section 6662; and (3) whether
petitioners are liable for the penalty pursuant to section 6673.
Background
None of the facts have been stipulated. At the time they
filed the petition, petitioners resided in Las Vegas, Nevada.
During 2001, petitioners received $216 from the Pennsylvania
State Employees Credit Union as interest income, $35,400 from
Advanced Entertainment Service as self-employment income, and
$19,522 from Defense Finance and Accounting Service as pension
income. Petitioners made no estimated tax payments for 2001.
Petitioners submitted a Form 1040, U.S. Individual Income
Tax Return, for 2001 to respondent. Petitioners listed zero as
the amount of their wages, total income, adjusted gross income,
taxable income, and total tax. Petitioners attached two pages to
the Form 1040 reciting statements, contentions, and arguments
that the Court finds to be frivolous and/or groundless.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011