Ruth Ann Gillings - Page 2

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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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