- 3 - Petitioner makes numerous tax protester arguments. Petitioner argues that he has a basis in his labor equal to his compensation and that therefore the $46,818 in compensation he received in 1993 does not constitute taxable income. Petitioner also argues that the Federal income tax constitutes an excise tax and that his compensation was not earned under any privilege or license on which an excise tax can be imposed. Courts have consistently held that compensation for services rendered constitutes taxable income and that taxpayers have no tax basis in their labor. Carter v. Commissioner, 784 F.2d 1006, 1009 (9th Cir. 1986); Olson v. United States, 760 F.2d 1003, 1005 (9th Cir. 1985); United States v. Romero, 640 F.2d 1014, 1016 (9th Cir. 1981); Abrams v. Commissioner, 82 T.C. 403, 407 (1984); Rowlee v. Commissioner, 80 T.C. 1111, 1119-1122 (1983). Courts have also rejected the argument that a taxpayer is liable for income tax only if the taxpayer has received a privilege or license on which an excise tax can be imposed. Olson v. United States, supra at 1005; United States v. Buras, 633 F.2d 1356, 1361 (9th Cir. 1980). Petitioner has stipulated that he received the $46,818 in question as compensation for services. We conclude that the $46,818 petitioner received in 1993 from Miliken & Co. constitutes taxable income. We also reject petitioner's other tax protester arguments.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011