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United States, 71 AFTR 2d 93-1735 at 93-1737, 93-2 USTC par.
50371 at 89,033 (D. Colo. 1993); see Beard v. Commissioner, 82
T.C. 766, 774-779 (1984), affd. 793 F.2d 139 (6th Cir. 1986);
Sickler v. Commissioner, T.C. Memo. 1994-462; Koeneman v.
Commissioner, T.C. Memo. 1958-186. Section 6501(c) provides that
in the case of a failure to file a return, the tax may be
assessed at any time. Since petitioner failed to file tax
returns for the years at issue, the notices of deficiency were
timely issued.
We hold that the wages and other income attributed to
petitioner in the notices of deficiency are taxable income. See
Coleman v. Commissioner, 791 F.2d 68, 70 (7th Cir. 1986). Gross
income is expressly defined under the Internal Revenue Code as
all income from whatever source derived, unless excluded by law,
including compensation for services and unemployment
compensation. Sec. 61(a), 85; secs. 1.61-1 and 1.61-2, Income
Tax Regs. Aside from her frivolous tax protester-type arguments,
petitioner offered nothing to contradict the determination of
wage and other income in the notices of deficiency, nor did she
offer any grounds for excluding those items from her gross
income.
Petitioner's general protester-type arguments have been
rejected by this Court and others, including the Court of Appeals
for the Seventh Circuit, to which appeal in this case lies. See
Coleman v. Commissioner, supra; see also Crain v. Commissioner,
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