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income tax return for the 1994 tax year. The IRS mailed similar
letters to petitioner for the 1989-93 tax years.
In a notice of deficiency dated April 18, 1997, respondent
determined a deficiency in petitioner's 1994 Federal income tax
in the amount of $2,644. The deficiency is based on petitioner's
failure to report wage income of $16,445, interest income of $50,
and unemployment income of $7,360. Respondent calculated the
deficiency based on single-filing status, one personal exemption
allowance, and the standard deduction.
In January 1998, after the filing of the petition in this
case, petitioner filed his 1994 Federal income tax return with
the IRS in Ogden, Utah. Petitioner sought to withdraw his Tax
Court petition and litigate the issue of the taxability of his
income in a United States District Court.2
OPINION
1. Federal Income Tax Exemption
Petitioner contends that he is exempt from Federal income
tax based on language contained in the Treaty of the Six
2 Petitioner's oral motion to withdraw his Tax Court petition
was made at the call of the calendar on Mar. 2, 1998, and was
denied.
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