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decision document to respondent. Thus far, no response
has been received.
Petitioner could have avoided causing further delay and expense
by executing and returning the stipulated decision document.
However, petitioner elected not to do so, or even to inform
respondent that he had changed his mind about doing so. Due to
the delay caused by petitioner’s initially agreeing to sign and
return the stipulated decision document and then failing to do
so, respondent was forced to file a motion to extend the briefing
schedule. The Court granted the motion and set dates for
respondent to file his opening brief, petitioner to file his
answering brief, and respondent to file his reply brief.
Respondent timely filed a posttrial opening brief setting forth a
detailed response to petitioner’s frivolous contentions.
Petitioner did not file a posttrial answering brief, and
respondent elected not to file an additional brief. Thereafter,
respondent filed a motion for an award of sanctions under section
6673.
1. Deficiency Determination
Petitioner’s wages, interest income, and distributions from
his individual retirement account are taxable as income. See,
e.g., United States v. Connor, 898 F.2d 942, 943 (3d Cir. 1990)
(“Every court which has ever considered the issue has
unequivocally rejected the argument that wages are not income”);
United States v. Richards, 723 F.2d 646, 648 (8th Cir. 1983)
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