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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
she did not believe that the tax laws required her to pay tax on
the income that she received. Petitioner continues to take that
position in her brief.
OPINION
Petitioner received wage income from various employers
during the years 1992, 1993, 1994, 1995, and 1996 in the
respective amounts of $17,840, $16,948, $21,297, $17,403, and
$20,091. Petitioner also received pension income during 1992,
1994, and 1995 in the respective amounts of $1,368, $6,102, and
$3,693.2 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
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