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Form W-2, petitioner submitted a Form 4852, Substitute Form W-2,
requesting a Form W-2 correction to indicate that he received no
“wages, tips or other compensation.” Throughout this course of
events, petitioner knew that the Form W-2 statement was entirely
accurate.
Petitioner also filed an unsigned Form 1040, U.S. Individual
Income Tax Return, indicating that he had no income, and no tax
liability. Apparently, the Internal Revenue Service Center
treated the unsigned Form 1040 as if it were a valid return, and
thus failed to determine a 25-percent addition to tax under
section 6651(a) for petitioner’s failure to file a timely tax
return. Instead, respondent determined in the notice of
deficiency that petitioner was liable for a 20-percent accuracy-
related penalty under section 6662(a). Also in the notice,
respondent determined an addition for failure to pay estimated
taxes under section 6654(a).
In his petition, petitioner states that he is not a tax
protester. He says our tax laws are very clearly written, and
provide that he need not pay tax on his income because he was not
engaged in an “excise taxable activity” for the tax period in
question.
On March 5, 2001, in compliance with the Court’s pretrial
order, petitioner filed a trial memorandum that we are treating
as his brief. Petitioner argues in his brief that he owes no
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