Sid L. Marquis - Page 3

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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.                                  
               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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