Edward J. Frami - Page 3

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          Federal income tax only applies to residents of Washington, D.C.            
          and U.S. territories.  Petitioner states that he is "a non-                 
          resident alien (American)".  His explanation also contains                  
          citations to a number of unrelated Internal Revenue Code sections           
          and cases that he concludes provide a basis for his not being               
          liable for Federal income tax.                                              
               For 1993 and 1994 petitioner was self-employed, and he                 
          conducted some income-earning activity from his residence.  He              
          was also an employee and/or officer of the United States                    
          Taxpayers Party of Wisconsin (Party).  For 1993, Party issued a             
          Form 1099-MISC, Miscellaneous Income, to petitioner in the amount           
          of $3,027, which represented Party's reimbursement of expenses to           
          petitioner of amounts over and above those incurred by petitioner           
          in the conduct of Party's activities during 1993.  For 1994,                
          Party changed its approach, and no Form 1099-MISC was issued to             
          petitioner.  Petitioner also received unemployment compensation             
          from the State of Wisconsin during 1993 in the amount of $2,173,            
          which was reported to petitioner and respondent by means of Form            
          1099-G, Certain Government Payments.                                        
               Due to the terse nature and format of petitioner's                     
          delinquent returns and petitioner's refusal to provide                      
          substantiation for the amounts reported in those returns,                   
          respondent's agent used a method of reconstruction to determine             
          the amount of petitioner's 1993 and 1994 income.  The method used           





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