- 11 - 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 whichPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011