Alan Michael Newman - Page 4

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               Respondent had little information regarding petitioner when            
          the tables representing petitioner's characteristics were                   
          selected.  Respondent was unsure how petitioner's age was                   
          determined.  Apparently, petitioner's race was presumed by the              
          revenue agent's observations.  Respondent did not have                      
          petitioner's specific physical address and used only a general              
          Bay Area statistic.  The record is silent regarding how                     
          petitioner's marital status and family composition were                     
          determined.  Respondent also classified petitioner as a renter;             
          however, the record is silent as to if and where a title search             
          was conducted.                                                              
               Petitioner did not file Federal income tax returns for the             
          taxable years in issue.                                                     
                                       OPINION                                        
          Issue 1.  Unreported Wages and Nonemployee Compensation                     
               Respondent determined that petitioner received and failed to           
          report wages and nonemployee compensation of $9,130, $12,158, and           
          $22,927 for 1990, 1991, and 1993, respectively.                             
               Petitioner does not challenge the merits of respondent's               
          determination.  Petitioner testified that he is not a tax                   
          protester.  Petitioner's arguments, however, consisted of                   
          hackneyed tax protester rhetoric that has been universally                  


               1(...continued)                                                        
          of the numbers shown therein.                                               




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