William C. Williams - Page 4




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          not subject to taxation and therefore not liable for income taxes           
          is without merit.  The short answer to petitioner's assertions is           
          that he is not exempt from Federal income tax.  See Abrams v.               
          Commissioner, 82 T.C. 403, 406-407 (1984).                                  
               Petitioner's arguments are wholly frivolous and have been              
          repeatedly rejected by this Court as well as the Court of Appeals           
          for the Fifth Circuit, the circuit to which an appeal would lie             
          in this case.  See, e.g., United States v. Price, 798 F.2d 111              
          (5th Cir. 1986); Anderson v. United States, 754 F.2d 1270 (5th              
          Cir. 1985); Lonsdale v. Commissioner, 661 F.2d 71 (5th Cir.                 
          1981), affg. per curiam T.C. Memo. 1981-122; Abrams v.                      
          Commissioner, supra; Rowlee v. Commissioner, 80 T.C. 1111 (1983);           
          Sochia v. Commissioner, T.C. Memo. 1995-475, affd. without                  
          published opinion 116 F.3d 478 (5th Cir. 1997).  Accordingly, we            
          hold that petitioner is liable for the deficiency in tax as                 
          determined by respondent.                                                   
               Section 6651(a) imposes an addition to tax for a taxpayer's            
          failure to file a required return on or before the specified                
          filing date, including extensions.  The addition to tax is                  
          inapplicable, however, if the taxpayer shows that the failure to            
          file the return was due to reasonable cause and not to willful              
          neglect.  See sec. 6651(a)(1).  It is undisputed that petitioner            
          failed to file a Federal income tax return for the year 1995.               
          Furthermore, petitioner has not provided this Court with any                






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