- 3 -
Petitioner also claims he is a non-domestic/non-resident/non-
taxpayer.
Petitioner makes similar contentions in his second amended
petition. He also asserts that "The wage tax cases [Abrams] v.
Commissioner, 82 T.C. 403 1984 - [Connor] v. Commissioner, 770
F 2 d 17 [2 cir. 1985] HAVE NO FOUNDATION". We disagree. As the
Court of Appeals for the Second Circuit stated: "A taxpayer has
no constitutional right to bring frivolous lawsuits." Connor v.
Commissioner, 770 F.2d 17, 19 (2d Cir. 1985), affg. per curiam an
unreported Order of this Court. The Second Circuit is the court
to which an appeal of this case may be taken.
Petitioner made additional arguments which we reject.
Suffice it to say that petitioner is not exempt from Federal
income tax. Abrams v. Commissioner, 82 T.C. 403, 407 (1984).
Payments of compensation for services performed are income. Sec.
61(a)(1).
In his amended petition and second amended petition,
petitioner makes tax protester arguments that have been
repeatedly rejected by this Court and others as inapplicable or
without merit. See, e.g., Rowlee v. Commissioner, 80 T.C. 1111
(1983); McCoy v.Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d
1234 (9th Cir. 1983). We see no need to repeat these discussions
here.
Rule 34(b)(4) and (5) provides in pertinent part that the
petition in a deficiency action shall contain "Clear and concise
assignments of each and every error which the petitioner alleges
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011