Wilson D. Watson - Page 2




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               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:                                                                 









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