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After a concession by petitioner,1 the remaining issues in
this case are: (1) Whether $33,339.05 received by petitioner for
his labor in 1996 is taxable wage income; (2) whether petitioner
is liable for the additions to tax for failure to timely file his
1996 Federal income tax return and for failure to pay estimated
tax; and (3) whether a penalty should be awarded to the United
States under section 6673.
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner resided in Tucson, Arizona.
We begin by noting that petitioner has been before this
Court on three prior occasions arguing the same issue, namely,
amounts reported on petitioner’s Form W-2, Wage and Tax
Statement, from his employment with the Family Life Broadcasting
System (FLBS) is not subject to income tax. See Howard v.
Commissioner, T.C. Memo. 2000-222 (involving tax years 1993
through 1995); Howard v. Commissioner, T.C. Memo. 1998-300
(involving tax years 1989, 1990, 1991, and 1993); Howard v.
Commissioner, T.C. Memo. 1998-57 (involving tax years 1987 and
1988). In each of petitioner’s prior cases before this Court, we
1 Petitioner conceded that he received interest income of $31
from Arizona Central Credit Union in 1996, and that such interest
income is taxable. Of the $31 interest paid, $9 was withheld by
Arizona Central Credit Union for Federal income taxes.
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