§66514

On December 27, 2005, respondent filed an answer which made specific affirmative allegations in-support of `establishing the additions to'tax under section 66514 ( f) for fraudulent failure=t o file returns for 2001 and 2002 .

Petitioner petitioned the Court to redeternine the deficiencies and additions to tax.¹ We must de ide whether: (1) Petitioner had unreported income in the amounts determined by respondent for 1998, 1999, 2000, and 2001; (2) petitioner is liable for the section 66514(a) addition to tax for 1998, 1999, 2000, and 2001; (3) petitioner is liable for the section 6654(a) addition to tax for 1998, 1999, and 2000; and (4) whether to impose a penalty pursuant to section 6673(a).