- 3 -
of $31,871.64, as well as Federal and State withholding taxes.
He also attached to the return a Form 1099R, Statements for
Recipients of Distributions From Pensions, Annuities, Retirement
or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.,
reporting from the Helicopters Federal Credit Union a $14,135.44
distribution from a qualified retirement plan.
Although petitioner overreported his wages as $33,965.872 on
the face of his Form 1040, he also included with the return a
Schedule D, Capital Gains and Losses. On the Schedule D he
reported as property held for 1 year or less "LABOR RECEIVED AS
GIFT [from God]" from 1-1-94 through 12-31-94, having a basis
equal to and a "sales" price of $33,965.87. He reported as an
asset held for more than 1 year the retirement plan distribution,
and also characterized it as payment for past labor received as a
gift from God having a basis equal to its sale price.
Petitioner included with the 1994 tax return two documents
he titled a "Statement" and a "Declaration". In the Statement he
expressed his belief that, upon his "study and understanding", he
was not "liable to the income taxes imposed by the Code." The
Statement declares that to the extent the Forms 1040 and 1099R
contradict the statements in his Declaration, "said forms are
2 This represents the amount of total Social Security wages
reported on petitioner’s Form W-2 from Helicopters for the year
1994 rather than wages includable in gross income. Respondent
concedes that petitioner overreported his wage income subject to
income tax by $2,094.23 ($33,965.87-$31,871.64).
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