Michael A. Cabirac v. Commissioner of Internal Revenue

Summary

The court held that the petitioner's wages, interest, and retirement-account distributions were taxable income and sustained the resulting deficiencies and the additional tax on early retirement distributions. It also sustained additions for failure to file valid returns and failure to pay estimated tax, but rejected the additions for failure to pay tax shown on a return because neither the petitioner's zero-entry forms nor the Commissioner's unsubscribed substitutes for return qualified under section 6020(b). The court imposed a $2,000 penalty because the petitioner's tax positions were frivolous.