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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).
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