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Not only has petitioner failed to adduce any evidence, his
legal arguments are frivolous. The courts have consistently and
uniformly held that wages are income and that a taxpayer has no
basis in his labor. See, e.g., Beard v. Commissioner, 793 F.2d
139 (6th Cir. 1986), affg. per curiam 82 T.C. 766 (1984); Coleman
v. Commissioner, 791 F.2d 68, 70 (7th Cir. 1986); Carter v.
Commissioner, 784 F.2d 1006, 1009 (9th Cir. 1986); United States
v. Burton, 737 F.2d 439, 441 (5th Cir. 1984); Funk v.
Commissioner, 687 F.2d 264, 265 (8th Cir. 1982), affg. per curiam
T.C. Memo. 1981-506.
Petitioner’s argument that Forms 1099R are invalid unless
signed under penalty of perjury is incorrect and is irrelevant to
whether he received a distribution. Under section 6065, except
as otherwise provided, a document required to be made under the
internal revenue laws or regulations must contain or be verified
under a written declaration that it is made under the penalties
of perjury. The Secretary has provided by way of regulation that
if a document is required by the regulations contained in chapter
61, or by the form and instructions issued with respect to the
document, to be verified by written declaration under penalties
of perjury, the document shall be so verified by the person
signing it. See sec. 1.6065-1, Income Tax Regs. Requirements
for reports on IRA distributions, however, are not found in
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Last modified: May 25, 2011