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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
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Last modified: November 10, 2007