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under section 6651(a)(1) are based on respondent's determination
that petitioner's failure to file timely income tax returns was
not due to reasonable cause. 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 years in
issue.
The petition, timely filed, contains the following
allegations: (reproduced exactly)
THE PETITIONER, UPON PRESENTMENT BY INTERNAL REVENUE,
RETURNED AND REFUSED FOR CAUSE UCC 3-501 SAID
PRESENTMENTS WITHOUT DISHONOR. IN ADDITION, PETITIONER
MARK NAGY, IS NOT A "U.S. CITIZEN" NEITHER IS HE A
'RESIDENT NOR INHABITANT' OF THE U.S. AND HAS NO INCOME
EFFECTIVELY CONNECTED WITH THE UNITED STATES THAT MARK
NAGY DID NOT KNOWINGLY OR VOLUNTARILY ENTER INTO ANY
AGREEMENT OR CONTRACT TO BE LIABLE FOR THE NATIONAL
DEBT, OR 'ELECTED' TO BE TREATED AS A RESIDENT OF THE
UNITED STATES UNDER 26 CFR PART 5h; 26 USC, SECTION
6013 (g) & (h) BY THE SIGNING OF FORM 1040 OR OTHER
RELATED U.S. FORMS. MARK NAGY IS NOT A PARTY TO ANY
TRANSACTION WITH THE U.S. LET THE U.S. PRODUCE THE
ORIGINAL SIGNED CONTRACT [SEC.] 871 4(b) FURTHER
PETITIONER SAYETH NOT.
After respondent filed the instant motion to dismiss,
petitioner filed an Objection in which he claims, inter alia,
that self-employment tax is an "excise-taxable" activity and that
3. Petitioner is a non-resident alien for purpose
of the Federal Excise Tax.
* * *
6. At issue in this case is the factual error the
Respondent made by classifying the Petitioner as a
resident of the U.S., and that the petitioner is
engaged in excise taxable activity. Since the
Petitioner was/is a non resident alien and not engaged
in any excise taxable activity he disputes [the
deficiencies, additions to tax, and interest].
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