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