- 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 alsoPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007