Charles P. Dewitt - Page 2

                                        Additions to tax                              
               Year     Deficiency      Sec. 6651(a)(1)  Sec. 6654                    
               1987      $4,921         $1,230         $266                           
               1988      4,455          1,114          283                            
               1989      1,946               342       87                             
               1990      3,540               282            57                        
               1991      3,971               291            49                        
               1992      5,142               803       132                            

               All section references are to the Internal Revenue Code in             
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
               In the notice of deficiency respondent determined that                 
          petitioner failed to file a Federal income tax return for any of            
          the years here involved.  The income determined as received by              
          petitioner was primarily self-employment income for the years               
          1987 and 1988, and wage income for the other years.                         
               Petitioner placed in issue in his petition all the                     
          deficiencies and additions to tax determined by respondent and              
          claimed an overpayment of $7,726.  In the petition, petitioner              
          states that he disagrees with the deficiencies determined                   
               As a result of the adoption of the 16th Amendment to                   
               the U.S. Constitution, the income tax is an indirect                   
               tax.  Indirect taxes are never upon property, money or                 
               otherwise, but only upon taxable activities.  All                      
               income received by Petitioner during tax years 1987-                   
               1992 arose from sources other than taxable activities.                 
               All the above is claimed in accordance with, but not                   
               limited to, 26 C.F.R. (1939) Section 39.22(b)-1(a),                    
               (see attached copy).                                                   

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