- 5 - Accordingly, petitioner has the burden of showing that respondent’s income tax deficiency determination is in error. Petitioner received income from wages and interest during his 2002 tax year. Petitioner has made several arguments in support of his position that respondent’s determination is either erroneous or “fraudulent”, but he has stipulated and has not otherwise denied the receipt of the wage and interest income for his 2002 tax year. We note that all of petitioner’s arguments are specious and without substance, and many of them have been offered by others who are merely attempting to avoid the payment of Federal tax. Accordingly, we hold that petitioner has not shown that respondent’s $8,044 income tax determination is in error. Next, we consider whether petitioner is liable for additions to tax under section 6651(a)(1) and (2) for failure to file a 2002 income tax return or to pay the tax due for that year. Section 6651(a)(1) provides for an addition to tax for failure to file, unless it is shown that the failure is due to reasonable cause and not due to willful neglect. Similarly, section 6651(a)(2) provides for an addition to tax for failure to pay the amount shown as tax on any return, unless it is shown that the failure is due to reasonable cause and not due to willful neglect.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011