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Petitioner was employed as an engineer during 1994 and 1995.
He received wages as compensation for the services he provided as
an engineer in the amounts of $34,775 and $42,106 in 1994 and
1995, respectively. Petitioner received rental income of $9,250
and $10,500 in 1994 and 1995, respectively. In 1994 and 1995,
petitioner received interest income of $125 and $144,
respectively. In 1996, petitioner received $284 of interest
income from two different sources, $34,936 as a distribution from
an individual retirement account (IRA) held by National Financial
Services Co., and $8,933 as a distribution from an IRA held by
Charles Schwab and Co., Inc. Petitioner had not reached the age
of 59� as of December 31, 1996, nor was he disabled as of this
date.
Petitioner timely filed his 1994 and 1995 tax returns. In
an attachment to the 1994 return, petitioner stated: "The wages
I earned as reflected on my W-2 form are nontaxable personal
property." The attachment also contained other typical tax
protester arguments. The 1995 return contained a similar
attachment. In 1994, $4,777 in Federal income tax was withheld
from petitioner's wages. There is no evidence that tax was
withheld in 1995. Yet, on both returns, petitioner claimed
refunds of $4,777. Petitioner did not file a 1996 tax return.
Respondent determined that petitioner had tax liabilities
for all 3 years in the amounts of the deficiencies listed above,
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