United States Tax Court, 1988

Gould v. Commissioner

United States Tax Court · Decided July 20, 1988

55 T.C.M. 1275; 1988 Tax Ct. Memo LEXIS 329; 1988 T.C. Memo. 304

Opinion

MARVIN A. GOULD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 26396-87.

United States Tax Court

T.C. Memo 1988-304; 1988 Tax Ct. Memo LEXIS 329; 55 T.C.M. (CCH) 1275; T.C.M. (RIA) 88304;

July 20, 1988.

*329 Marvin A. Gould, pro se.

Lisa Primavera-Femia, for the respondent.

RUWE

MEMORANDUM OPINION

RUWE, Judge: Respondent determined a deficiency in petitioner's 1984 Federal income tax and additions to tax as follows:

	Additions to Tax
Deficiency	Sec. 6653(a)(1) ¹	Sec. 6653(a)(2)
$ 548	$ 27	50 percent on
		interest due on
		$ 548

The issues for decision are whether petitioner received interest income from various financial institutions which he failed properly to report, and whether petitioner is liable for additions to tax under section 6653(a) for negligence.

Petitioner's testimony at trial consisted of vague references to various constitutional and statutory provisions and numerous Biblical passages. Petitioner was advised by the Court several times to direct his testimony to the facts in the case; specifically any facts related to omitted interest income. Petitioner failed to present any*330 evidence concerning his income or financial transactions during the year 1984.

Petitioner bears the burden of proof with respect to the disputed deficiency and additions to tax. ; Rule 142(a). Petitioner has failed to meet his burden of proof.

Decision will be entered for the respondent.

Footnotes

1. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and as in effect during the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. ↩

Case-law data current through December 31, 2025. Source: CourtListener bulk data.