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the wages that he earned as a pilot for American Airlines during
the taxable years 1983 through 1987.
Respondent's answers in these cases include specific
assertions that petitioner failed to report wage income from
American Airlines and that he filed false Forms W-4 with American
Airlines claiming to be exempt from income tax withholding with
the fraudulent intent to evade tax.
Petitioner filed replies to respondent's answers alleging in
pertinent part that: (1) He is not a "taxpayer" but rather is a
"sovereign citizen and resident of the Republic of the State of
California"; (2) his wages from American Airlines do not
constitute taxable income; and (3) Form W-4 does not apply to him
on the ground that he is not a taxpayer.3
Subsequent to the filing of petitioner's replies, respondent
filed motions for partial summary judgment that petitioner is
liable for tax deficiencies attributable to his failure to report
the wages that he received from American Airlines for the taxable
years 1983 through 1987. Petitioner filed oppositions to
respondent's motions again asserting that he is a nonresident
3 Petitioner made similar tax protester type arguments in
separate proceedings before this Court concerning his liability
for the 1980 and 1988 taxable years. In response, the Court, on
its own motions, awarded damages to the United States in the
respective amounts of $5,000 and $2,000 pursuant to sec. 6673(a).
See Fox v. Commissioner, T.C. Memo. 1993-277, affd. without
published opinion 69 F.3d 543 (9th Cir. 1995) (1988 tax year);
Fox v. Commissioner, T.C. Memo. 1989-232, affd. without published
opinion 943 F.2d 55 (9th Cir. 1991) (1980 tax year).
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