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($2,696.00 and $674.00) were subtracted from the corrected tax
liability reducing the deficiency and addition to tax amounts
determined in the notice of deficiency. On August 22, 1997,
respondent issued separate notices of deficiency, for the years
1994 and 1995.
OPINION
Deficiency Determinations
On brief, petitioner argues that the presumption of
correctness does not apply and that respondent has failed to
prove that petitioner received taxable income for the years in
issue. We disagree. The notices of deficiency were based on
information obtained from FLBS and from petitioner’s own
statements. At trial, a representative of FLBS testified that
FLBS paid petitioner for his services in the amounts determined
in the notices of deficiency and petitioner admitted at trial
that he received those amounts from FLBS in return for his
services.
Petitioner has made various other claims, including that
payments for his labor are not income, that he has a basis in
such labor equal to the amount of the payments received, that the
income tax is unconstitutional, and that he was a nonresident
alien with no relationship to the Government of the United
States. All of these arguments have been consistently rejected
by the courts and can be accurately characterized as timeworn
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