Randal W. Howard - Page 4




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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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