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Background
Petitioner resided in Colorado Springs, Colorado, when he
petitioned the Court in this case.
Petitioner did not file a Federal income tax return for
2003. Respondent issued a notice of deficiency to petitioner
determining that petitioner failed to report taxable retirement
distributions of $41,657, dividend income of $241, and interest
income of $3; that petitioner was liable for an income tax
deficiency of $9,507; and that petitioner was liable for
additions to tax under sections 6651(a)(1) and (2) and 6654.
On August 24, 2005, petitioner timely petitioned for
redetermination of the deficiency and the additions to tax. In
his petition, petitioner disputed the full amount of the
deficiency and the additions to tax3 and alleged that there was a
multitude of errors in respondent’s determinations. However,
most of the allegations in the petition either were
unintelligible or, if intelligible, were frivolous.4 Petitioner
3Petitioner alleged in his petition that respondent had
determined “deficiencies” in income tax for 2003 of $12,368, all
of which is in dispute. The amount represents the total tax,
penalties, and interest (computed to Apr. 24, 2005) due from
petitioner as shown on Form 4549, Income Tax Examination Changes
(included as part of the notice of deficiency).
4For example, petitioner argued that he was not required to
file an information request for 2003, that he was not required to
file a return because respondent’s form violated the provisions
of the Paperwork Reduction Act, and that he was not liable for
any increase in tax for 2003 “pursuant to 44 U.S.C. � 3512.”
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Last modified: May 25, 2011