Lavonne Allen Hodgson - Page 3

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          determination.  In his pretrial memorandum, petitioner stated that          
          "his self assessment determined that he was not a 'taxpayer' as             
          that word of art is used in the Internal Revenue Code".  He further         
          stated that he was not engaged in any taxable activity that would           
          subject him to income tax. At trial, petitioner presented no                
          evidence to refute respondent's deficiency determination.                   
               Instead of attempting to challenge the merits of respondent's          
          determinations, petitioner raises the usual "tax protester"                 
          arguments which we and other courts have always rejected.  See,             
          e.g., Wilcox v. Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg.          
          T.C. Memo. 1987-225.  We do not believe it appropriate to address           
          petitioner's assertions as to the validity of the Federal income            
          tax system "with somber reasoning and copious citation of                   
          precedent; to do so might suggest that these arguments have some            
          colorable merit."  Crain v. Commissioner, 737 F.2d 1417, 1417 (5th          
          Cir. 1984).  Suffice to say, section 61(a)(1) includes in gross             
          income compensation for services rendered, and it is undisputed             
          that petitioner received $67,337 as wages from services rendered to         
          the Northrop Grumman Corp.                                                  
               Respondent's deficiency determinations are presumed correct,           
          and the burden is on petitioner to show that the determinations are         
          wrong.  Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933).               

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