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At the hearing on respondent's motion, petitioner made an
oral motion to continue, which was denied as untimely under Rule
134. Petitioner presented no other argument.
If the Commissioner determines a deficiency in income tax,
the Commissioner is authorized to send a notice of deficiency by
certified or registered mail to the taxpayer. Secs. 6211 and
6212; secs. 301.6211-1 and 301.6212-1, Proced. & Admin. Regs. A
taxpayer has 90 days (150 days if addressed to a person outside
the United States) from the mailing of a notice of deficiency
within which to file a petition with the Tax Court challenging
the determined tax liability. Sec. 6213; sec. 301.6213-1,
Proced. & Admin. Regs. This is the route petitioner chose to
follow.
We find that the notice of deficiency in this case complies
with the applicable statutes and reject petitioner's contentions
as to its validity.
Section 61 provides that gross income means "all income from
whatever source derived," including (but not limited to)
"Compensation for services", "Gains derived from dealings in
property", "Interest", "Dividends", and "Pensions". Petitioner's
contention that he is not subject to taxation and therefore not
liable for income taxes is without merit. The short answer to
petitioner's assertions is that he is not exempt from Federal
income tax. Abrams v. Commissioner, 82 T.C. 403, 406-407 (1984).
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