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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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Last modified: May 25, 2011