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FLBS prepared a 1996 Form W-2 for petitioner showing wage
income of $33,339.05 and Federal income tax withheld of
$1,167.15. Petitioner did not make any payments to the Internal
Revenue Service for the 1996 taxable year other than the
withholdings. Petitioner did not file a Federal income tax
return for the 1996 taxable year.
In a notice of deficiency, respondent determined that
petitioner received taxable wage income of $33,339.05.
Respondent also determined that petitioner was liable for
additions to tax for failure to file a Federal income tax return
for the 1996 taxable year and failure to pay the estimated tax
liability.
At the close of trial, respondent orally moved to impose
sanctions under section 6673. A written motion was filed on
March 22, 2001.
This Court and Federal courts across the nation have
repeatedly rejected petitioner’s arguments that amounts he
received from FLBS do not constitute wage income and that
reporting and paying income taxes are strictly voluntary. Woods
v. Commissioner, 91 T.C. 88, 90 (1988); Howard v. Commissioner,
T.C. Memo. 2000-222; Howard v. Commissioner, T.C. Memo. 1998-57.
We find petitioner’s arguments baseless and wholly without merit.
As petitioner’s arguments have been addressed by this and other
courts, we need not exhaustively review and respond to them.
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