- 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