- 5 - authority of the United States to tax his income. At trial, we reserved our right to rule on that motion at a later time; we proceeded under the assumption that this Court has jurisdiction. OPINION Issue 1. Motion to Dismiss for Lack of Jurisdiction Petitioner asserts that this Court lacks jurisdiction to hear his case. Respondent asserts that petitioner's arguments are standard tax protester rhetoric and have long since been rejected by this Court. It suffices to say that petitioner chose this forum in which to litigate his tax dispute. The Court acquired jurisdiction in this case after a valid notice of deficiency was sent to petitioner, and he in turn filed a timely petition. Secs. 6212(a) and (b), 6213(a); Minovich v. Commissioner, T.C. Memo. 1994-39. Once the Court's jurisdiction is invoked, it remains unimpaired until we decide the controversy. Dorl v. Commissioner, 57 T.C. 720, 722 (1972), affd. per curiam without opinion 507 F.2d 406 (2d Cir. 1974). Accordingly, petitioner's motion to dismiss for lack of jurisdiction is denied. Issue 2. Unreported Income Respondent determined deficiencies in petitioner's gross income for the years at issue. Petitioner asserts that he is a nonresident alien "without" the taxing authority of the United States. Respondent asserts that petitioner is liable for tax onPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011