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impose a penalty pursuant to section 6673.
All section references are to the Internal Revenue Code, as
amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
Background
At the time of filing the petition in the instant case,
petitioner resided in Greenville, South Carolina. Petitioner is
affiliated with the “Patriot Network”, a tax protester
organization that promotes tax protester arguments. Petitioner
failed to file Federal income tax returns and pay taxes for
taxable years 1998, 1999, 2000, 2001, and 2002. Based on Forms
1099 issued by third parties, respondent determined that
petitioner had received: (1) Interest income of $13, $21, $30,
$39, and $1,881 in taxable years 1998 through 2002, respectively;
and (2) $12,948 of taxable pension income during each taxable
year in issue. Respondent determined deficiencies in income tax
and section 6651(a)(1) and section 66542 additions to tax and
sent petitioner separate notices of deficiency for each taxable
year in issue. Respondent computed the deficiencies using the
tax rates under section 1(c) for an unmarried individual who is
not a head of household or a surviving spouse. Respondent also
determined that petitioner was entitled to one personal exemption
and one standard deduction for each tax year. Petitioner timely
2Respondent now concedes the sec. 6654 additions to tax.
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Last modified: May 25, 2011