John S. Cooper, Jr. - Page 5

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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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