Vivan D. Rodriguez - Page 2

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          7443A(b)(3) and Rules 180, 181, and 182 by order of the Chief               
          Judge.  In the notice of deficiency, respondent determined a                
          deficiency in petitioner's Federal income tax for the taxable               
          year 1989 in the amount of $2,366, additions to tax under                   
          sections 6651(a)(1) in the amount of $1,192, and 6654(a) in the             
          amount of $159, and a penalty under section 6662(a) in the amount           
          of $473.                                                                    
               The adjustments giving rise to the above deficiencies,                 
          additions to tax, and penalty are based upon the failure of                 
          petitioner to file a tax return for 1989 and report wages of                
          $20,873.  Petitioner, a California resident, alleges in the                 
          petition that she is "an individual, American citizen (Domestic)            
          not a United States citizen and/or resident living abroad                   
          (National)" and that the addition to tax under section 6651(a)(1)           
          only applies to Alcohol, Tobacco, and Firearms revenue.                     
          Petitioner also alleges that she does not know the meaning of               
          "wages" and that she has been denied due process.  She alleges              
          that she has not been engaged in "any other taxable activity                
          other than employment, all of which was within the jurisdictional           
          boundaries of the State of California."  Thus she contends that             
          taxes relating to "EMPLOYMENT" are not subject to the deficiency            
          procedures of section 6211.  Petitioner makes further allegations           
          in the petition, which are common in tax protester petitions,               

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