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Respondent also determined additions to tax under section
6651(a)(2). In each of the answers, respondent conceded the
additions to tax under section 6651(a)(2) and, accordingly,
alleged increases in the additions to tax under section
6651(a)(1). The issue remaining for decision is whether a
penalty should be awarded to the United States under section
6673. Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
All of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in Calverton, New York, at the time that he
filed his petitions. The petitions alleged no facts showing
errors in respondent’s determinations but set forth frivolous tax
protester arguments, including that “petitioner could find no
statute or regulation making petitioner liable for an income
tax”. In his petitions, petitioner admitted that he failed to
file Federal income tax returns for 2001 and 2002.
After these cases were set for trial, respondent sent to
petitioner requests for admissions for each year, setting forth
the items of income received by petitioner, petitioner’s failure
to file income tax returns for either year, and petitioner’s
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Last modified: May 25, 2011