Frederick M. Fox - Page 5

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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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