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Respondent determined a deficiency of $4,387 in petitioner’s
2002 Federal income tax, a section 6654 addition to tax of
$146.61, and a section 6651(a)(1) addition to tax of $1,096.75.
The issues for decision are: (1) Whether petitioner is liable
for the deficiency determined by respondent; (2) whether
petitioner is liable for an addition to tax pursuant to section
6654; (3) whether petitioner is liable for an addition to tax for
failure to file a Federal income tax return pursuant to section
6651(a)(1); and (4) whether petitioner is liable for a penalty
for making frivolous arguments or instituting a proceeding
primarily for delay pursuant to section 6673(a)(1).
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed in this case, petitioner resided in New Harmony, Utah.
Respondent received information from third parties regarding
various payments made to petitioner for the 2002 tax year.
Petitioner does not dispute the receipt of these payments.
Petitioner submitted a Form 1040, U.S. Individual Income Tax
Return, for 2002 to respondent. Petitioner listed zero as the
amount of his wages, total income, adjusted gross income, taxable
income, and total tax. Petitioner attached a typewritten
statement to the Form 1040 reciting contentions and arguments
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