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Except where otherwise indicated, all section references are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
This case is before the Court on various outstanding
motions. The issues for decision are: (1) Whether to grant
respondent's motion to dismiss for lack of prosecution; (2)
whether to grant petitioner's motion for summary judgment; and
(3) whether to grant respondent's motion for a section 6673
penalty.
When petitioner Stephen V. Talmage filed his petition in
this case, he resided in Piedmont, South Carolina.
Petitioner, an employee of United Parcel Service, Inc.
(UPS), filed no Federal income tax return for 1991. On the basis
of statements sent to respondent by the payors, respondent, in
her notice of deficiency, dated October 7, 1994, attributed to
petitioner wages of $41,520 from UPS, nonemployee compensation of
$24,801 from Matol Botanical International, Montreal, Canada, and
dividend income of $60 from the Common Sense Growth Fund.
In his petition, filed January 5, 1995, petitioner asserted
various tax protester arguments (e.g., that he was not subject to
the jurisdiction of the Internal Revenue Service; that he was not
a taxpayer or person as defined in the Code; and that tax forms
issued by Internal Revenue Service failed to display OMB numbers
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