- 2 - 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’sPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011