Gene and Ciao Newman - Page 5




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               Even though we know that no section of the Internal                    
               Revenue Code:                                                          
               1) established an income tax “liability” * * * ;                       
               2) provides that income taxes “have to be paid on the                  
               basis of a return” * * * .                                             
                              *   *   *   *   *   *   *                               
               In addition to the above, we are filing even though:                   
                    3. The “Privacy Act Notice” that the face of this                 
               return directs us to, states that we need only file a                  
               return for “any tax” we may be “liable” for, and since                 
               no Code section makes us “liable” for income taxes,                    
               this Notice notifies us that we do not have to file an                 
               income tax return.                                                     
                              *   *   *   *   *   *   *                               
                    It should also be noted that we had “zero” income                 
               according to the Supreme Court’s definition of income                  
               * * * .                                                                
               The word “income” is not defined in the Internal                       
               Revenue Code * * * but, as stated above, it can only be                
               a derivative of corporate activity.                                    
               B.  Respondent’s Deficiency Notices and Petitioners’                   
          Responses                                                                   
               On May 4, 1998, respondent issued two notices of deficiency            
          to petitioner Gene Newman (petitioner).  In the first notice,               
          respondent determined a deficiency in the amount of $2,036 in               
          petitioner’s Federal income tax for 1993 and an addition to tax             
          under section 6651(a)(1) in the amount of $475.  In the second              
          notice, respondent determined a deficiency in the amount of                 
          $1,781 in petitioner’s Federal income tax for 1994 and an                   







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