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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.
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Last modified: May 25, 2011