- 14 -
penalties and additions to tax on the ground that she is too busy
to keep up with her tax obligations.
The deductions claimed on the S corporation returns that
petitioner produced have not been substantiated. Even taking
them at face value, however, for 2000, petitioner received wages
($325,304) and S corporation profits ($116,493) exceeding the
total wages and medical payments determined in the statutory
notice ($405,007). For 2001 and 2002, the income reported on the
S corporation returns substantially exceeded the medical payments
income discovered by respondent as a result of third-party
reporting. Although it is not clear whether or when the S
corporation returns were filed, use of a different Social
Security number for petitioner apparently resulted in the
corporation’s net income’s not being included in the notices of
deficiency. Petitioner’s recalcitrance has made it impossible to
determine with confidence the precise amount of her taxable
income. On the entire record, however, we cannot conclude that
the deficiencies are excessive. Thus, we do not believe that
justice requires that petitioner be provided any further
opportunities to cure her prior defaults.
Petitioner has repeatedly asserted that respondent’s counsel
and the Court are biased against pro se litigants. She has made
other spurious charges. Petitioner’s claims are totally without
merit. The Court’s orders and Rules take into consideration that
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