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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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