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Petitioner does not argue that he did not receive payment
for the "sale" of his labor in 1994, 1995, or 1996. Petitioner’s
argument is instead based on his "gift" theory of the taxability
of wages. His Statement attached to the 1994 tax return declares
the Forms W-2 and 1099R to be erroneous as well as his listing
the Helicopters payments as wages. On Schedule D attached to the
return, petitioner treated his wages as property held for 1 year
or less, "LABOR RECEIVED AS GIFT [from God]", having a basis
equal to its sales price.
Petitioner does not argue that he did not receive an IRA
distribution in 1994. Petitioner's position is that such
distributions represent nontaxable payments received from past
"sales" of labor at no "gain". He also argues that the Form
1099R reporting an IRA distribution to him in 1994 is invalid
unless it is "signed under the penalty of perjury", citing
section 6065.
Upon analysis of the record in this case, we find that
petitioner has not disputed his connection with the tax-
generating income ascribed to him by respondent. Respondent
determined for the year 1994 that petitioner received an
unreported IRA distribution, and for 1995 and 1996, unreported
income the amount of which was determined by using BLS
statistics. The closest petitioner has come to a denial of the
receipt of income is in his amended petition. The amended
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