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in 1991. Petitioner received $6,868 in nonemployee compensation
from Geographic General in 1991. Petitioner received $886 in
nonemployee compensation from the University of Wisconsin in
1991. Petitioner received $65,6392 in nonemployee compensation
from Xerox Corp. in 1992.
The parties agree that petitioner incurred deductible travel
expenses as follows which were not taken into account in the
notice of deficiency. In December 1991, petitioner incurred
deductible travel expenses of $1,177. Further, during 1992, in
connection with his relationship with Xerox Corp., petitioner
incurred $7,513 in deductible travel expenses.
On October 30, 1995, this case was called for trial in
Denver, Colorado. At trial, petitioner failed to offer any
evidence to support his case, documentary or testimonial;
instead, he attempted to pursue tax protester arguments that have
been long rejected by this Court.
On brief, petitioner argues that the tax respondent is
attempting to impose on his nonemployee compensation, earned as a
computer systems analyst, is an excise tax for which he is not
responsible. Petitioner claims that the Internal Revenue
Service, by collecting this excise tax and treating him as a
"taxpayer", exceeds its statutory authority. Petitioner's
2This amount of $65,639 reflects a concession by respondent,
who originally asserted that petitioner received $123,538 in
nonemployee compensation for the 1992 tax year.
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