- 2 - 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 argumentsPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011