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checks to petitioner from Hawthorne in 1991 totaling $6,134.263
were introduced into evidence.
For the balance of the year 1991, when not working for
Hawthorne, petitioner worked for himself. Petitioner introduced
into evidence a Form 1099-MISC from "Giving You Credit", Inc.,
reporting $29 of nonemployee compensation that he received in
1991. Throughout the year 1991, petitioner lived in a house for
which he paid rent and utilities.
Respondent examined petitioner's 1990 and 1991 taxable years
and determined that petitioner had unreported wage income for
both years, had unreported interest income in 1990, had
unreported self-employment income in an amount determined by
Bureau of Labor Statistics figures for 1991, failed to make
required estimated tax payments in both years, and failed to file
Federal income tax returns for both years.
Discussion
Respondent's determinations are presumed correct, and
petitioner bears the burden of proving otherwise. Rule 142(a);
INDOPCO, Inc. v Commissioner, 503 U.S. 79, 84 (1992); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
Petitioner's objections to respondent's adjustments are
those typical of so-called tax protestors. In his trial
memorandum petitioner alleges that: (a) He was born a
3The statutory notice of deficiency makes an adjustment to
petitioner's income for 1991 in the amount of $8,530 for "wages".
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