Rosa Janus - Page 11

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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                  
               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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