- 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’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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