- 2 -
Additions to Tax/Penalties, I.R.C.
Year Deficiency Sec. 6651(a)(1) Sec. 6654 Sec. 6662(a)
2000 $147,076 - - $29,415.20
2001 341,684 $85,431 $13,654.96 -
2002 345,892 85,223 11,373.05 -
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Petitioner failed to comply with various orders prior to the
date set for trial, failed to present evidence concerning her
income or deductions at the time of trial, was held in default
but given an opportunity to cure the default, and failed to make
any bona fide effort to cure the default. The issue for decision
is whether respondent’s determinations should be sustained in
full by reason of petitioner’s default. We have reviewed the
entire record to determine whether such a sanction is too severe
under the circumstances and have decided that it is not.
Background
Petitioner is a physician who resided in West Virginia at
the time that she filed her petitions. For 2000 and 2002, she
filed Forms 1040, U.S. Individual Income Tax Return, in which she
inserted zeros in each line calling for information concerning
income, deductions, or computations of tax. Attached to each of
the Forms 1040 was a frivolous statement contending that
petitioner did not have taxable income and containing various
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011