Philip Lewis Hart - Page 3

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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              
               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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