T.C. Memo. 2007-146
UNITED STATES TAX COURT
WILSON D. WATSON,1 Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 18616-03, 18991-03, Filed June 12, 2007.
19206-03, 16592-04.
R rejected the Forms 1040 submitted by P for 1998,
1999, 2001, and 2002 (all of which reported zero tax
owed) as frivolous and prepared substitute returns
pursuant to which he determined deficiencies for all 4
years and additions to tax under secs. 6651(a)(1),
I.R.C., (for all years), 6651(a)(2), I.R.C., (for 2002)
and 6654, I.R.C., (for 1999 and 2001). R conceded
certain income inclusions for all years, the addition
to tax under sec. 6651(a)(2), I.R.C., and the 2001
addition to tax under sec. 6654, I.R.C. R’s income
inclusions, after concessions, consist of (1)
“wages/misc. income” for 1998 and 1999, (2) retirement
distributions for all years, (3) interest income for
1998, and (4) Social Security payments for 2001 and
2002. R also asks us to impose a penalty under sec.
1 The cases were consolidated by orders of the Court dated
Feb. 17 and Oct. 13, 2004.
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Last modified: November 10, 2007