- 4 -
together with the additions to tax and penalties. Respondent's
determinations in the statutory notices of deficiency are
presumed correct, and petitioner bears the burden to disprove the
determinations. Rule 142(a); Welch v. Helvering, 290 U.S. 111
(1933). Respondent concedes that petitioner did not receive
refunds of California State income tax in the amounts of $774 and
$1,431 in 1994 and 1995, respectively, which had been included in
the calculations of the deficiencies for those years.
Petitioner first argues that the statutory notices of
deficiency were not authentic. At trial, we found that all
requirements of the notice of deficiency had been satisfied for
all 3 years. Petitioner next argued: "when I read the statutes
and the regulations, I do not find in them where there is a tax
on the wages, that's payable by me. It's conceivable there could
be a tax payable by somebody else, but it's not payable by me."
Petitioner makes tax protester arguments that have been
repeatedly rejected by this Court and others as inapplicable or
without merit. Rowlee v. Commissioner, 80 T.C. 1111 (1983);
McCoy v. Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d 1234
(9th Cir. 1983). We see no need to repeat these discussions
here.
Suffice it to say that petitioner is not exempt from having
to pay Federal income taxes. Abrams v. Commissioner, 82 T.C.
403, 407 (1984). Payments of compensation for services performed
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011