- 3 - $5,920, unemployment compensation of $3,705, interest of $20, dividends of $36, and wages of $20,131. Petitioner did not file income tax returns for 1990, 1994, or 1996. I. Unreported Income Respondent determined that all of petitioner’s receipts during the years in issue were income to petitioner. Petitioner does not dispute that he received the income; rather, he contends there is insufficient authority to hold him liable for an income tax. The crux of petitioner’s argument is found in his trial memorandum and supplement to trial memorandum.4 These trial memoranda are merely lists of disjointed brief quotations and erroneous statements of law. Giving petitioner the benefit of the doubt, we construe petitioner’s argument to be that the income tax is unconstitutional and, alternatively, that the definition of income excludes his receipts. We reject 4The Court directed the parties to file simultaneous briefs, together with simultaneous reply briefs. Petitioner did not file a brief. We could declare petitioner in default and dismiss his case. See Rule 123; Stringer v. Commissioner, 84 T.C. 693 (1985), affd. without published opinion 789 F.2d 917 (4th Cir. 1986); Pace v. Commissioner, T.C. Memo. 2000-300. We also could conclude that petitioner abandoned his claims after trial and decide this case against petitioner because he failed to meet his burden of proof. See Calcutt v. Commissioner, 84 T.C. 716, 721- 722 (1985); Hartman v. Commissioner, T.C. Memo. 1999-176. We choose, instead, to decide the case on the merits in the hope that this opinion will guide petitioner’s future decisions regarding his tax obligations. See Calcutt v. Commissioner, supra at 721-722; Pace v. Commissioner, supra; Bissell v. Commissioner, T.C. Memo. 1991-163.Page: Previous 1 2 3 4 5 6 7 8 Next
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