Joseph T. McQuatters - Page 11

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            probative information" concerning the deficiency beyond the                                 
            information return has not shifted to respondent.  Petitioner is                            
            a nonfiler and a typical tax protester.  When petitioner's                                  
            nonfiling status was brought to the attention of respondent                                 
            through information returns filed by unrelated third parties,                               
            petitioner responded with classic tax protester arguments, and to                           
            the extent possible, stonewalled respondent by refusing to                                  
            provide any information or records concerning his income in 1988.                           
            Section 6201(d) does not provide a means for a taxpayer to avoid                            
            his Federal income tax liabilities by failing to file a tax                                 
            return, refusing to provide any information to the Commissioner                             
            or the Court, and refusing to provide any records concerning his                            
            income.  Respondent's determinations concerning petitioner's 1988                           
            income from self-employment and interest are sustained.                                     
                  In the statutory notice of deficiency, respondent determined                          
            that in 1988 petitioner received unreported nonemployee                                     
            compensation from Masterguard in the amount of $20,309, which was                           
            subject to self-employment tax.  Section 1401 imposes a tax on                              
            the "self-employment income" of every individual.  "Self-                                   
            employment income" is defined generally in section 1402(b) as                               
            "the net earnings from self-employment derived by an individual *                           
            * * during any taxable year".  Section 1402(a) defines the term                             
            "net earnings from self-employment" as the "gross income derived                            
            by an individual from any trade or business carried on by such                              
            individual, less the deductions allowed by this subtitle which                              




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