- 2 - 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.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011