- 12 - 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 isPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011