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by levy of petitioner’s income tax liability for 2000. We
sustain respondent’s determination for reasons discussed below.
FINDINGS OF FACT
1. Petitioner
Petitioner resided in Florida when he filed his petition.
Petitioner was a professional pilot in 2000 and had the following
amounts of income:
Payor Amount Description
Bombardier Aerospace Corp. $68,305 Nonemployee compensation
Bombardier Aerospace Corp 58,045 Wages
PE Corp. NY 1,333 Nonemployee compensation
Florida Agency for Workforce 825 Unemployment compensation
Innovation
Natl. Financial Services LLC 362 Dividends
Bank of America 281 Interest
Space Coast Credit UN 145 Interest
First National Bank of
Suffield 140 Interest
Total 129,436
2. Petitioner’s Form 1040 for 2000
On August 17, 2001, petitioner submitted a Form 1040, U.S.
Individual Income Tax Return, for 2000 to respondent. In it, he
stated that his filing status was married filing separately. He
entered zeros on the lines provided for reporting his income and
tax and requested a refund of $9,316. Petitioner attached to the
Form 1040 a document in which he claimed, inter alia, that: (a)
No section of the Internal Revenue Code makes him liable for
income tax; (b) no section of the Internal Revenue Code requires
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