Philip Lewis Hart - Page 4

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          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                
               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           

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