Darold D. Friesen and Rosella M. Friesen - Page 3

                                        - 3 -                                         
          1990 from Santa Rosa Sales and Marketing, Inc.  The addition to             
          tax under section 6651(a)(1) is based on respondent's                       
          determination that petitioner failed to file a timely income tax            
          return for the taxable year 1990.                                           
          Petitioners' Petition                                                       
               Petitioners filed a petition for redetermination on July 31,           
          1995.  In their petition, petitioners allege that they are "non-            
          federal people" who are inhabitants of the Republic State,                  
          Nebraska, which is "without" the United States.  In this regard,            
          petitioners claim "status as defined at CFR 1.871-1(b)(i)".2  The           
          petition also includes the following allegations, among others:             
                    The Petitioners are Non-Residents of Washington,                  
               D.C., they are non-Residents of any Federal area, and                  
               are alien to the foreign Federal Jurisdiction;                         
                              *   *   *   *   *   *   *                               
                    The Petitioners are not now, nor have they ever                   
               been "transferees" of the federal funds for their                      
               livelihood;                                                            
                    The Petitioners find no Treasury Dept. delegation                 
               of Authority Order that has been issued or published,                  
               which would provide for finding deficiencies or                        
               assessing them as inhabitants in the Republic State,                   
               Nebraska;                                                              






          2 For purposes of the income tax, sec. 1.871-1(b), Income                   
          Tax Regs., sets forth 3 classes of nonresident alien individuals.           
          The first such class, described in sec. 1.871-1(b)(1)(i), Income            
          Tax Regs., consists of nonresident alien individuals who at no              
          time during the taxable year are engaged in a trade or business             
          in the United States.                                                       


Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011