- 8 - washed the airplane. The record does not indicate how often Mr. Frank did those things. Petitioner spoke with flight schools (not otherwise identified in the record) to find the best rate for leasing, maintaining, and insuring the airplane. Petitioner reported a $2,773.52 loss for the airplane in 1991 and a $3,672.39 loss in 1992. OPINION A. Whether Petitioners Are Exempt From Federal Income Tax Petitioners contend that they are not subject to Federal income tax because Mr. Frank is a "common laborer" and has an "occupation of common right". Petitioners also contend that they revoked their tax returns for the years at issue and that, as a result, they have no contract with respondent; that they are not taxpayers; and that we lack jurisdiction because they moved to withdraw their petition, which we denied. We disagree. We have jurisdiction over this case because respondent properly issued notices of deficiencies to petitioners for the years in issue and petitioners timely filed a petition with this Court. Secs. 6212(a) and 6213(a); Stamos v. Commissioner, 95 T.C. 624, 626 (1990), affd. without published opinion 956 F.2d 1168 (9th Cir. 1992). Wages are income and a tax on wages is constitutional. Coleman v. Commissioner, 791 F.2d 68, 70 (7th Cir. 1986); Crain v. Commissioner, 737 F.2d 1417, 1417-1418 (5th Cir. 1984). Mr. Frank received wages for his work as a nuclear engineer at aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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