Janine H. Hansen - Page 3

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          is not reviewable by any other court, and this opinion should not           
          be cited as authority.  The issues for decision are whether                 
          petitioner is liable for tax relating to unreported income and              
          for the section 6651(a)(1) and (2) additions to tax relating to             
          2000, 2001, and 2002.                                                       
                                     Background                                       
               Petitioner is the president of the State of Nevada Eagle               
          Forum, a State chapter of the National Eagle Forum.  In 2000,               
          2001, and 2002, petitioner annually received $6,000 of non-                 
          employee compensation from a foundation associated with the                 
          National Eagle Forum (the foundation), yet petitioner did not               
          file tax returns relating to those years.  In a notice of                   
          deficiency dated April 5, 2005, respondent determined that                  
          petitioner is liable for tax deficiencies totaling $2,544,                  
          section 6651(a)(1) additions to tax for failure to file a return,           
          and section 6651(a)(2) additions to tax for failure to timely pay           
          taxes relating to 2000, 2001, and 2002.  At trial, on January 30,           
          2006, respondent moved for the imposition of a section 6673(a)(1)           
          penalty.                                                                    
               On May 31, 2005, petitioner, while residing in Sparks,                 
          Nevada, filed her petition.                                                 
                                     Discussion                                       
               Petitioner concedes that she received income and failed to             
          report the amounts determined by respondent.  Petitioner                    






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