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FINDINGS OF FACT
During 2003, petitioner was employed as a respiratory
therapist at Washoe Health Systems, Inc. (Washoe), and earned
$54,756. Petitioner did not file a tax return or pay estimated
taxes relating to 2003. On April 26, 2005, respondent issued
petitioner a statutory notice of deficiency relating to 2003 in
which he determined additions to tax, pursuant to sections
6651(a)(1) and 6654(a), for failure to file a return and make
estimated tax payments, respectively. Petitioner paid the
liability but did not pay the additions to tax.
Petitioner, while residing in Sparks, Nevada, filed her
petition with this Court.
OPINION
Respondent has the burden of production relating to the
section 6651(a)(1) and 6654(a) additions to tax. See sec.
7491(c); Rule 142(a). Petitioner admitted that she failed to
file her return and pay estimated income taxes relating to 2003.
See Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Petitioner
may, however, be excused from the section 6651 and 6654 additions
to tax if an exception applies. See id. at 447.
Petitioner contends that the section 6651 and 6654 additions
to tax are not applicable because her parents raised her to
believe that the Internal Revenue Service was an illegal
organization and taught her not to file tax returns or pay taxes.
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Last modified: May 25, 2011