David Loven Nelson v. Commissioner of IRS

Appellant David Nelson appeals pro se the tax court’s decision upholding the Commissioner of the Internal Revenue Service’s (“the Commissioner”) deficiency determinations for tax years 2005 and 2008. According to the Commissioner, Nelson had a tax deficiency in 2005 of $40,153, and was assessed penalties of: (1) $9,034.43 under I.R.C. § 6651(a)(1); (2) $1,610.62 under § 6654(a); and (3) $9,837.49 under § 6651(a)(2). In 2008, Nelson’s tax deficiency was $86,440, and he was assessed penalties of: (1) $12,112.20 under § 6651(a)(1); and (2) $3,499.08 under § 6651(a)(2). The record shows that,…