- 3 - contends, however, that she is not liable for tax on these payments because of her religious beliefs. The Supreme Court has held that “Because the broad public interest in maintaining a sound tax system is of such a high order, religious belief in conflict with the payment of taxes affords no basis for resisting the tax.” United States v. Lee, 455 U.S. 252, 260 (1982); see also Adams v. Commissioner, 110 T.C. 137 (1998), affd. 170 F.3d 173 (3d Cir. 1999). Accordingly, petitioner is liable for the tax relating to the payments from the foundation. See sec. 61(a). Respondent bears, and has met, the burden of production with respect to the section 6651(a)(1) and (2) additions to tax. See sec. 7491(c); Rule 142(a). Petitioner does not meet the requirements of any exception to section 6651(a)(1) or (2). Accordingly, respondent’s determinations are sustained. See Higbee v. Commissioner, 116 T.C. 438, 446 (2001). Respondent contends that petitioner’s position is frivolous and that, pursuant to section 6673(a)(1), the Court should impose a penalty on petitioner. We, however, conclude that it is not appropriate to impose such a penalty in this case. Contentions we have not addressed are irrelevant, moot, or meritless.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011