Michael L. Goers - Page 3

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          compensation from others.  Petitioner, at trial and on brief,                
          presented an array of legal positions, all of which appear to be             
          in support of his contention that he is not subject to 26 U.S.C.             
          or, more particularly, the income tax.  To the extent necessary,             
          we consider petitioner’s following arguments.                                
          A.  The Income Tax Is Based on a Voluntary Self-Assessment System            
               Essentially, petitioner argues that he must agree to self-              
          assess, or respondent must make a proper assessment of any tax,              
          which must include the signature of an authorized official.  In              
          this regard, respondent prepared a substitute for return under               
          section 6020(b)1 in order to establish a record for petitioner’s             
          1994 tax year.  Petitioner contends that the substitute for                  
          return is unsigned, and accordingly no assessment can be made                
          against petitioner.                                                          
               Initially, we note that petitioner’s contentions about the              
          proper assessment of tax are premature because this forum is                 
          designed for a prepayment (prior to assessment) controversy that             
          is prerequisite to the Commissioner’s authority to assess certain            
          taxes.  See secs. 6211-6213.  With respect to the voluntary                  
          nature of the income tax, that position has been unsuccessfully              

               1  Section references are to the Internal Revenue Code, as              
          amended and in effect for the period under consideration.  Rule              
          references are to this Court’s Rules of Practice and Procedure.              

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