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from Northbrook Life Insurance Co., a completed Schedule K, and
other documents showing distributions or payments to petitioners.
On April 19, 1995, petitioners sent to respondent a document
entitled "joint income tax return, 1994". This document was not
a Form 1040 but was a document generated by petitioners. This
document did contain specific dollar amounts in various places,
including an attached Schedule A, Form 2106, Forms 1099, Schedule
K, documents from Dean Witter, and Forms W-2. The document
created by petitioners differed in significant respects from the
Commissioner's Form 1040, including the form of the jurat.
Respondent used transcripts of petitioners' information
returns from 1992 through 1994 to compute the deficiencies
determined in the notices of deficiency. After the notices were
issued, petitioners produced their books and records to
respondent and respondent made a number of concessions.
In papers filed with respondent and with the Court,
petitioners argue that Federal income taxes violate various
amendments of the U.S. Constitution and that so-called Fifth
Amendment returns are valid. In oral argument, petitioners also
asserted that section 61(a) is incompatible with the 16th
Amendment of the Constitution.
OPINION
Petitioners do not contest that they received the wages,
interest, and other amounts determined by respondent in the
notices of deficiency. They argue instead that these amounts are
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