- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION WHERRY, Judge: These consolidated cases are before the Court on petitions for judicial review of statutory notices of deficiency dated November 28, 2005. After concessions,1 the issues for decision are: (1) Whether petitioner is liable for additions to tax under sections 6651(a)(1) and (2) and 6654(a) for the two taxable years at issue;2 and (2) whether the Court should impose a penalty under section 6673(a)(1). FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts and accompanying exhibits are hereby incorporated by reference. At the time he filed his petitions, petitioner resided in Loudon, Tennessee. Petitioner failed to file Federal income tax returns for the 2000 and 2001 taxable years until February 23, 2007.3 Petitioner 1 Petitioner has conceded the deficiencies, as increased in accordance with the computations of respondent’s counsel, infra at 4, and at trial sought to discuss only his liability for the additions to tax and the sec. 6673(a)(1) penalty that respondent has asked the Court to impose. 2 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the years in issue. 3 Petitioner also never filed a Federal income tax return (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007