- 11 -
provide a tax exemption for U.S. source income of U.S. citizens,
including Williams v. Commissioner, 114 T.C. 136 (2000), and
Aiello v. Commissioner, T.C. Memo. 1995-40. He quoted our
statement in Williams v. Commissioner, supra at 138-139, that:
“Petitioner’s arguments are reminiscent of tax-protester rhetoric
that has been universally rejected by this and other courts.” He
also quoted that portion of our report in Aiello in which we
refer to the position of the Court of Appeals for the Ninth
Circuit:
The Court of Appeals for the Ninth Circuit, to which
any appeal in this case will lie, has stated,
“Compensation for labor or services, paid in the form
of wages or salary, has been universally held by the
courts of this republic to be income, subject to the
income tax laws currently applicable.” United States
v. Romero, 640 F.2d 1014, 1016 (9th Cir. 1981). * * *
He stated: “Although you apparently understood our arguments in
this case, you dismissed them as ‘a normal response from a tax
collector’. But you provide no support for your interpretation
of sections 61 and 861. Please provide us with any cases
supporting your position.” He warned Mr. Sulla that respondent
would seek a penalty against petitioner under section 6673(a)(1)
and was considering asking the Court to impose costs on Mr. Sulla
pursuant to section 6673(a)(2).
Mr. Sulla reiterated the 861 argument in his declaration
attached to petitioner’s “Memorandum in Opposition to Motion for
Summary Judgment and Motion for Damages” (sometimes, petitioner’s
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011