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Petitioner's 1997 amended return was not processed by the
Internal Revenue Service as a return but was instead treated as a
claim for refund, which was disallowed.
In the notice of deficiency for 1998, respondent determined
that the $60,461 petitioner earned from the company during 1998
constituted salary or wage income. In the notice of deficiency
for 1997, respondent determined that petitioner failed to include
in income a State income tax refund of $2,540 petitioner received
that year.
Petitioner conceded the State income tax refund for 1997 but
contends he made an overpayment of taxes for 1997 because of his
inclusion of the wages he received from the company that year.
For 1998, petitioner contends the wages he received that year
from the company are not includable in gross income.
Petitioner contends that, because he and the other employees
of the company forfeited certain rights they otherwise possessed
as employees under the collective bargaining agreement, they were
reduced to what he referred to as "nonentities", and, as such,
their income is not taxable. Petitioner argues that he and his
fellow employees were reduced to a status "less than all other
taxpayers" and, therefore, should not be liable for Federal
income taxes.
Petitioner cited no authority for his position, and, indeed,
there is no such authority to support his position.
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