- 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