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Respondent issued a statutory notice of deficiency to
petitioner determining that he had failed to report the receipt
of an IRA distribution of $2,619 for 1994, was liable for the
10-percent additional tax on early distributions from qualified
retirement plans, had failed to report income for 1995 and 1996
(determined by the Bureau of Labor Statistics (BLS)), and had
failed to file timely a tax return for each of the 3 years 1994
through 1996.
Petitioner filed an amended petition with the Court alleging
error on respondent's part in failing to allow him "deductions,
allowances and credits", proceeding "as if" he had IRA income in
1994, or any income in 1995 and 1996, and in attempting to impose
a direct or indirect tax upon his income, if any. The facts upon
which he based his allegations of error are: (a) He "had
expenses for the deductions, allowances and credits for the
maintenance of his home and care of his family, including his
wife and 2 children"; (b) assuming that the bank that held the
IRA made payments to him in 1994, it did not send him a notice
signed under penalties of perjury that it had made payments to
him; (c) he was neither an employee nor self-employed during 1995
and 1996; and (d) respondent is attempting to impose improperly a
direct tax without apportionment or an indirect tax "without
identifying the commodity or material consumed."
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