- 3 -
and 6654, and interest (collectively, the 1992 liability). Aside
from a withholding credit of $42 and a payment of $800, the 1992
liability was unpaid at the time of trial.
Petitioner filed a Federal income tax return for 1993,
received by respondent on June 10, 1994, that reported tax due of
$9,142. Respondent assessed the reported tax, as well as
additions to tax under sections 6651(a)(1), 6651(a)(2), and 6654,
and interest (collectively, the 1993 liability). The 1993
liability was unpaid at the time of trial.
On March 5, 1997, respondent received from petitioner a Form
1040, U.S. Individual Income Tax Return, for 1996 with zeros in
all entries and an attached statement containing frivolous tax
protester arguments.2 Respondent treated the Form 1040 as a
frivolous return and assessed a frivolous return penalty under
section 6702 on June 29, 1998.
On March 31, 1997, respondent received a Form 1040X, Amended
U.S. Individual Income Tax Return, from petitioner for 1993 with
zeros in all entries in the "Correct amount" column and an
attached statement substantially identical to the one attached to
the 1996 Form 1040. On April 1, 1997, respondent received
similar Forms 1040X from petitioner for 1990 and 1991.
2 The arguments included, e.g., "no Code section makes me
'liable' for income taxes" and "'income' * * * can only be a
derivative of corporate activity", as well as out-of-context
quotations from case law, statutes, and regulations.
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