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failed to pay the requisite amount of estimated income taxes for
1991, 1992, and 1993.
On June 16, 1995, petitioner filed a petition in which he
disputes all of the deficiencies and additions to tax. In his
petition he also alleges that although he is a "state citizen of
Illinois [not State of Illinois]", he is not a United States
citizen2, or "resident alien", and is not a nonresident alien
that is engaged in a U.S. trade or business.
Respondent filed an answer to the petition on July 10, 1995,
followed on August 14, 1995, by the subject motion for summary
judgment.
By Order dated August 17, 1995, this matter was set for
hearing in St. Louis, Missouri, on October 2, 1995. The case was
called for hearing on that date and both petitioner and counsel
for respondent appeared. At the hearing, respondent waived oral
argument in support of her motion. Petitioner's oral argument
consisted of the usual, patently frivolous, tax protester
arguments.
Although admitting to "having a job" and to receiving
"compensation" for his work, petitioner nevertheless takes the
position that for the years 1991 through 1993, he was not subject
to Federal income tax because: (a) "26 C.F.R." is not published
2In an attempt to have his cake as well as eat it,
petitioner states, in a document denominated "Affidavit in
Support of Petition", that Illinois is "united by and under the
Constitution of the United States."
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