Lawrence W. Wirenius - Page 3




                                        - 3 -                                         

               On a weekly basis, petitioner would submit an invoice to               
          Clairmont for the amount of hours spent during the week on the              
          development of the quiet camera room.  These invoices were                  
          approved by an officer of Clairmont and paid.  Clairmont did not            
          withhold any income or Social Security tax from the payments to             
          petitioner.  Petitioner did not receive any employee benefits               
          from Clairmont, such as annual leave, sick leave, or pension.               
               Petitioner did not file a Federal income tax return for                
          1994.  Respondent’s records also reflect that petitioner did not            
          file a Federal income tax return for 1993.  Petitioner testified            
          and we find that petitioner did not have any income in 1993.                
               This case is basically a case involving a nonfiler who                 
          refuses to acknowledge liability under the Internal Revenue Code            
          and who has asserted various tax protester arguments.  However,             
          petitioner did engage in discussions of the merits of the case              
          with respondent, did enter into a stipulation of facts and                  
          supplemental stipulation of facts, and did testify under oath as            
          to the merits of respondent’s determination.  We shall first                
          address the issues which we do not categorize as tax protester              
          issues.                                                                     
               1. Gross Income  Petitioner worked for Clairmont during 1994           
          and received $25,836.92.  Respondent admits that only $22,455 was           
          compensation for labor.  Petitioner also agrees that the                    
          $25,836.92 was not all compensation for his labor and that he did           
          receive $22,455 as compensation for his labor.  Compensation for            
          labor is includable in a taxpayer’s gross income.  Sec. 61(a).              

Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011