Steven Matthew Langley - Page 3

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            The deficiencies include self-employment taxes and, for the                                   
            taxable years 1990 and 1991, the deduction authorized by section                              
            164(f) for one-half of such taxes.  The deficiency for 1991 does                              
            not take into account income tax withheld from petitioner's                                   
            wages.  Sec. 6211(a), (b)(1).                                                                 
                  The additions to tax under section 6651(a)(1) are based on                              
            respondent's determination that petitioner's failure to file                                  
            timely income tax returns for the taxable years in issue was not                              
            due to reasonable cause.  Finally, the additions to tax under                                 
            section 6654(a) are based on respondent's determination that                                  
            petitioner failed to pay the requisite estimated income tax for                               
            the taxable years in issue.                                                                   
            Petitioner's Petition                                                                         
            Petitioner filed a petition for redetermination on December                                   
            29, 1995.  The petition admits that "All monies paid to me have                               
            been wages" and alleges that "Only income is taxable, not wages                               
            or salaries".  The petition also alleges as follows:                                          
                  There is not enough pages to submit all the U.S. court                                  
                  cases to prove that income is taxable and wages are                                     
                  not.  Tax on wages are volentary [sic].  I do not wish                                  
                  to participate.                                                                         
            Respondent's Rule 40 Motion and Subsequent Developments                                       
                  As indicated, respondent filed a Motion To Dismiss For                                  
            Failure To State A Claim And To Impose A Penalty Under I.R.C. �                               
            6673 on February 16, 1996.  Respondent's motion concludes as                                  
            follows:                                                                                      





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