Stanley C. Wolcott - Page 2




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                       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...)           





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