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Commissioner, 115 T.C. 324, 328-329 (2000). Thus, we will
dismiss this case for lack of jurisdiction.
2. Whether we will decide if the hearing requirement under
section 6330(b) has been met. We hold that we will not. We will
no longer follow Meyer v. Commissioner, 115 T.C. 417 (2000), to
the extent that it holds to the contrary.
References to petitioner are to David J. Johnson.
Background
Petitioners lived in Milton, Florida, when they filed the
petition in this case.
A. Petitioners’ Tax Returns
Petitioners filed returns for 1994, 1995, and 1996, in which
they reported their wages as income. They later filed amended
returns for those years in which they did not report any income,
and contended that wages and salary reported as income on their
original returns are not taxable. In attachments to each of
those amended returns, petitioners stated:
1. No section in the Internal Revenue Code makes
petitioners liable for the income taxes at issue.
2. Income is not defined in the Internal Revenue Code.
3. The Supreme Court defines income as corporate profit.
4. Wages are not corporate profit; thus, petitioners have
no income.
5. Section 61 is invalid because it defines “gross income”
by using the word “income”.
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