- 11 -
say that: Petitioner is a taxpayer subject to the Federal income
tax, see secs. 1, 7701(a)(1), (14); sec. 1.1-1(a)(1) and (b),
Income Tax Regs.; compensation for labor or services rendered
constitutes income subject to the Federal income tax, sec.
61(a)(1); United States v. Romero, 640 F.2d 1014, 1016 (9th Cir.
1981); gross income derived from business and unemployment
compensation is also subject to the Federal income tax, secs.
61(a)(2), 85(a); and in case of failure to file a return, tax may
be assessed at any time, see sec. 6501(c)(3). See also Madge v.
Commissioner, T.C. Memo. 2000-370 (rejecting as frivolous the
contention that only foreign income is subject to Federal income
tax), affd. 23 Fed. Appx. 604 (8th Cir. 2001); cf. Corcoran v.
Commissioner, T.C. Memo. 2002-18 (rejecting as frivolous the
contention that income earned by U.S. citizens from sources
within the United States is excluded from U.S. taxation under the
source rules of the Internal Revenue Code).
We likewise conclude that the Appeals officer obtained
verification from the Secretary that the requirements of all
applicable laws and administrative procedures were met as
required by section 6330(c)(1). The record shows that the
Appeals officer obtained and reviewed a TXMODA transcript of
account with regard to petitioner’s taxable year 1992.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. “The summary record, through supporting
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011