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
indicated.
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
because:
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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Last modified: May 25, 2011