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return for 2000, 2001, or 2002. Respondent prepared a Form
4549A, Income Tax Examination Changes, and issued to petitioner a
notice of deficiency dated January 23, 2006, that determined the
following deficiencies in petitioner’s Federal income tax and
additions to tax:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6651(a)(2) Sec. 6654
2000 $185,170 $41,663.25 See * below $9,890.85
2001 90,250 20,306.25 See * below 3,606.72
2002 82,605 18,586.13 See * below 2,760.39
With regard to the section 6651(a)(2) addition to tax for each
year, the note marked by the “*” stated that “The amount of the
addition to tax cannot be determined at this time, but an
addition to tax of .5 percent will be imposed for each month, or
fraction thereof, of nonpayment, up to 25 percent, based on the
liability shown on this report.”
Petitioner, while residing in Wheat Ridge, Colorado, timely
petitioned this Court. In his petition, petitioner denies being
a “subject” liable to tax and argues, among other things, that he
has, by his actions, relinquished his “subject” status of “U.S.
citizenship” and that this Court lacks jurisdiction to decide the
case.
1(...continued)
Internal Revenue Code. Rule references are to the Tax Court
Rules of Practice and Procedure.
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Last modified: May 25, 2011