Robert S. Brooks - Page 2




                                        - 2 -                                         

                                 MEMORANDUM OPINION                                   

               NIMS, Judge:  Respondent determined a deficiency of $13,876            
          in petitioner’s Federal income tax for 2002.  Respondent also               
          determined additions to tax of $3,122.10 for failure to file a              
          return under section 6651(a)(1), $1,040.70 for failure to pay tax           
          shown on a return under section 6651(a)(2), and $463.69 for                 
          failure to pay estimated tax under section 6654(a).                         
               Petitioner objects to paying the income tax on numerous                
          grounds, all of which are protester-type arguments.  The issues             
          for our determination are whether respondent correctly determined           
          petitioner’s tax liability and the additions to tax.                        
               Both parties have moved for summary judgment pursuant to               
          Rule 121.  Unless otherwise indicated, all section references are           
          to the Internal Revenue Code in effect for the tax year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
                                     Background                                       
               At the time he filed the petition in this case, petitioner             
          resided in West Virginia.                                                   
               In 2002, petitioner received W-2 income in the amount of               
          $68,708 from the Arlington County School Board.  He also                    










Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next 

Last modified: November 10, 2007