Kevin James Cullinane - Page 3




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               Petitioner makes numerous tax protester arguments.                     
          Petitioner argues that he has a basis in his labor equal to his             
          compensation and that therefore the $46,818 in compensation he              
          received in 1993 does not constitute taxable income.  Petitioner            
          also argues that the Federal income tax constitutes an excise tax           
          and that his compensation was not earned under any privilege or             
          license on which an excise tax can be imposed.                              
               Courts have consistently held that compensation for services           
          rendered constitutes taxable income and that taxpayers have no              
          tax basis in their labor.  Carter v. Commissioner, 784 F.2d 1006,           
          1009 (9th Cir. 1986); Olson v. United States, 760 F.2d 1003, 1005           
          (9th Cir. 1985); United States v. Romero, 640 F.2d 1014, 1016               
          (9th Cir. 1981); Abrams v. Commissioner, 82 T.C. 403, 407 (1984);           
          Rowlee v. Commissioner, 80 T.C. 1111, 1119-1122 (1983).                     
               Courts have also rejected the argument that a taxpayer is              
          liable for income tax only if the taxpayer has received a                   
          privilege or license on which an excise tax can be imposed.                 
          Olson v. United States, supra at 1005; United States v. Buras,              
          633 F.2d 1356, 1361 (9th Cir. 1980).                                        
               Petitioner has stipulated that he received the $46,818 in              
          question as compensation for services.  We conclude that the                
          $46,818 petitioner received in 1993 from Miliken & Co.                      
          constitutes taxable income.  We also reject petitioner's other              
          tax protester arguments.                                                    






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