- 6 - notice of deficiency, nor any underlying liability determined by 26 U.S.C. �� 6012 or 6020(b). 121. The Petitioner is not liable for any increase in tax of $9,619.40 for tax year 2003, pursuant to 44 U.S.C. � 3512. 122. The Petitioner is not liable for a penalty at 26 U.S.C. � 6651(a)(2) in the amount of $529.07 for tax year 2003, pursuant to 44 U.S.C. � 3512. 123. The Petitioner is not liable for a penalty at 26 U.S.C. � 6651(a)(1) in the amount of $2,164.37 for tax year 2003, pursuant to 44 U.S.C. � 3512. 124. The Petitioner is not liable for a penalty at 26 U.S.C. � 6654 in the amount of $248.21 for tax year 2003, pursuant to 44 U.S.C. � 3512. 125. The Petitioner is not liable for interest under IRC 6601 in the amount of $594.47 for tax year 2003, pursuant to 44 U.S.C. � 3512. 126. The Petitioner is not liable for total deficiencies in the amount of $13,155.51 for tax year 2003, pursuant to 44 U.S.C. � 3512. 127. Conversely, the Respondent is liable to Petitioner for an amount in excess of $2,500 as reimbursement of any administrative costs, court costs and any other expenses Petitioner has expended by reason of Respondent’s erroneous determination. Petitioner failed to submit to the Court a pretrial memorandum as required by the Court’s standing pretrial order. On the day of trial, the Court filed respondent’s motion for sanctions pursuant to section 6673. Petitioner failed to testify at trial and rested his case after his opening statement. OPINION 1. Unreported Income Section 61(a) provides that “gross income means all income from whatever source derived”. Gross income is an inclusive term with broad scope, designed by Congress to “exert * * * ‘the full measure of its taxing power.’” Commissioner v. Glenshaw GlassPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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