- 3 -
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:
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011