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extent of its fair market value minus the amount (if any) paid
for the property. In attempting to equate his wages with
property for which he has a tax cost, petitioner's argument is
nothing more than a variation of the wages-are-not-income claim
frequently advanced by tax protesters, and it is completely
without merit. Gammon v. Commissioner, T.C. Memo. 1996-4;
Santangelo v. Commissioner, T.C. Memo. 1995-468. Cf. Crow v.
Commissioner, T.C. Memo. 1995-584. Petitioner's argument fails
for the same reason that other protesters' arguments fail; the
worker's cost for his services--and thus his basis--is zero, not
their fair market value.
We will therefore deny petitioner's motion for summary
judgment and grant summary judgment to respondent.
Issue 2. Section 6673 Penalty
Respondent has also moved that we impose a penalty against
petitioner under section 6673(a) of $25,000 or such other amount
as we deem appropriate because petitioner's positions are
frivolous and groundless and he instituted and maintained this
proceeding primarily for delay.
We have imposed section 6673 penalties on taxpayers who have
made frivolous tax protester arguments. Coleman v. Commissioner,
791 F.2d 68, 72 (7th Cir. 1986) (wages not income), affg. an
Order of this Court; Granzow v. Commissioner, 739 F.2d 265,
267-268 (7th Cir. 1984) (wages not income), affg. per curiam 3
decisions, (i) an Order of this Court, (ii) Basic Bible Church v.
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