- 2 - 6673(a)(1), I.R.C. P puts forth frivolous tax- protester arguments in opposition to R’s proposed income inclusions and additions to tax. 1. Held: R’s nonconceded inclusions in P’s income for 1998 and 1999 are sustained. 2. Held, further, P had zero includable Social Security benefits for 2001 and 2002, and, because his adjusted gross income without those benefits is less than his standard deduction and personal exemption, he incurs no income tax deficiencies for those years. 3. Held, further, P is liable for additions to tax under sec. 6651(a)(1), I.R.C., for 1998 and 1999 and for an addition to tax under sec. 6654, I.R.C., for 1999. 4. Held, further, because P was not required to file returns for 2001 and 2002, he is not liable for additions to tax under sec. 6651(a)(1), I.R.C., for those years. 5. Held, further, P is liable for a penalty under sec. 6673(a)(1), I.R.C. Wilson D. Watson, pro se. Randolph J. Buchanan, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: By notices of deficiency, respondent determined deficiencies in income tax and additions to tax for petitioner’s taxable (calendar) years 1998, 1999, 2001, and 2002 as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007