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returns. Petitioner has not filed any other income tax returns
for the years in issue.
In correspondence with respondent, petitioner indicated that
he did not believe that the tax laws required him to pay tax on
the income that he received. Petitioner continues to take that
position in his brief.
OPINION
Petitioner received wage income from the U.S. Postal Service
during each of the years 1994, 1995, and 1996 in the respective
amounts of $34,490, $35,261, and $35,428. Petitioner also
received pension income during 1994, 1995, and 1996 in the
respective amounts of $6,258, $6,420, and $6,591.2 Petitioner
generally argues that no act of Congress authorizes taxation of
these amounts. We disagree. All these amounts constitute gross
income under section 61. Petitioner’s arguments to the contrary
are wholly without merit and not worthy of further analysis. We
hold that petitioner has deficiencies in income taxes in the
amounts determined in the notice of deficiency.
Respondent also determined that petitioner is liable for
additions to tax pursuant to section 6651(f) for fraudulent
failure to file returns for each of the years in issue. The
2In computing the amount of the deficiencies, respondent
determined that petitioner was liable for an increase in tax of
10 percent on the pension distributions pursuant to sec. 72(t).
Petitioner has not disputed this and offered no evidence on this
point.
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Last modified: May 25, 2011