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tax purposes. His argument was disjointed, as reflected in his
testimony at trial:
It is that wages have been found to be property by courts.
Property, in order to tax that, that would be in effect
servitude of the taxpayer, making them, basically taking -–
I don't know how to phrase it exactly, but * * *. Well,
wages are not included in what is commonly called gross
income in the Tax Code. In fact, as property, it would be
taxable as ordinary income under the Tax Code, which the
only ordinary income which is taxed is real estate. So,
therefore, there is no actual tax put on wages as property.
When the Court pointed out to petitioner that section
61(a)(1) defines gross income to mean all income from whatever
source derived including, but not limited to, compensation for
services, his response was that the compensation he received as
an employee "would be corporate services". Petitioner agreed
that he was not a corporation: "my position is that the income
tax is on corporations and not on individuals. When it refers to
compensation for services, it's referring to services rendered by
a corporation." The Court rejects that reasoning.
Petitioner's argument is completely lacking in factual and
legal foundation and constitutes a textbook case of a protest of
the Federal tax laws. Such protester arguments have been heard
on numerous occasions by this Court, as well as other courts, and
have been consistently rejected. The Court sees no need to
further respond to petitioner's arguments with somber reasoning
and copious citations of precedent, as to do so might suggest
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