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memorandum): “[T]he clear and unequivocal language contained
under the several provisions of 26 CFR � 1.861 shows that the
income of United States citizens from the remuneration of
services from sources within the United States are not included
as taxable or non-exempt income.” The 861 argument is also
contained in petitioner’s memorandum of points and authorities in
opposition to motion for summary judgment, which is signed by Mr.
Sulla.
Also attached to petitioner’s memorandum is petitioner’s
affidavit. Attached to the affidavit are Exhibits, including an
Exhibit B, a letter to the Internal Revenue Service, dated April
11, 2001, in which, among other things, petitioner states:
pursuant to the filing of the attached and completed
IRS Form(s) I hereby challenge, controvert and/or
refute any and all claims that I made any “wages” as
defined in Title 26 United States Code(USC) � 3401(a)
and/or that I received any remuneration from any source
for the afore said year(s) that is includable in “gross
income”, as defined in the operative sections of the
IRC as listed in Title 26 Code of Federal Regulations
(CFR) � 1.861-8(f)(1). * * *
2001 Trial Session
At the 2001 trial session, Mr. Sulla attempted to show cause
why we should not make absolute our orders sanctioning him and
petitioner under section 6673(a). He attempted to show the good
faith of his argument that the wages and interest received by
petitioner in 1996 are exempt from Federal income taxation. He
stated as a factual predicate for his argument that petitioner is
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