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his Fifth Amendment rights; and that his wages do not constitute
“income” within the meaning of the Internal Revenue Code, on the
basis of his interpretation of the “Corporation Excise Tax Act
(of 1909)” and on a theory that only corporate-derived income
constitutes taxable income.
B. Notices of Deficiency and Petitioner’s Responses
On October 10, 1997, and February 6, 1998, respondent
(acting through Jimmy L. Smith, Director of the Internal Revenue
Service (IRS) Service Center in Cincinnati, Ohio) issued
petitioner notices of deficiency for 1995 and 1996, respectively;
and on May 28, 1999, respondent (acting through R. Wayne Hicks,
Director of the IRS Service Center in Cincinnati, Ohio) issued
petitioner a notice of deficiency for 1997. In these notices,
respondent determined deficiencies in, and additions to,
petitioner’s Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1995 $8,826 $1,788.00 $324.00
1996 11,990 2,857.55 605.09
1997 20,465 5,058.25 1,081.10
The deficiencies were based on respondent’s determination
that petitioner failed to report wage income as reported to
respondent by Nationwide Communications, Inc., on Forms W-2, Wage
and Tax Statement.
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