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USA, Inc.; Carmax Auto Superstores, Inc. (Carmax); and Primerica
Shareholder Services. Based on the information returns,
respondent determined that petitioner earned the following in
wage and dividend income for said years:
Year Amount
1998 $22,055
1999 39,102
2000 34,637
2001 24,943
The notices of deficiency were issued December 17, 2003.
Petitioner is a part-time consultant in sales and marketing.
During the years in question, petitioner also sold copiers on
behalf of Minolta and Ikon and automobiles on behalf of Carmax.
Petitioner reluctantly admitted she was paid by each of the
companies for her services but maintains that such payments do
not constitute taxable income.
At trial, petitioner argued that the notices of deficiency
were invalid; however, she offered no evidence to substantiate
that claim. Petitioner’s testimony throughout trial was limited
to legal arguments that respondent had failed to provide her with
“full disclosure” pursuant to 26 U.S.C. section 6303(a) (2000)
and accusations that this Court and the laws of the United States
are unduly prejudiced against her and were “seeking to enslave”
her. Furthermore, petitioner claimed that the notices of
deficiency for the subject years were “officially dead and mute”
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