- 9 -
of deficiency at his last known address for 1999. See sec.
6212(a) and (b).
Accordingly, because petitioner received a notice of
deficiency for 1999 and did not petition this Court for a
redetermination, petitioner is precluded from challenging his
underlying tax liability for 1999 in this collection action.
Sec. 6330(c)(2)(B).
2. Wages Are Not Income
Petitioner argues that his wages are not taxable income.
His arguments are indistinguishable from those that have been
uniformly rejected, and no further discussion of them is
warranted. See United States v. Connor, 898 F.2d 942, 943 (3d
Cir. 1990); Coleman v. Commissioner, 791 F.2d 68, 70 (7th Cir.
1986); Sauers v. Commissioner, 771 F.2d 64, 66 (3d Cir. 1985),
affg. T.C. Memo. 1984-367; Connor v. Commissioner, 770 F.2d 17,
20 (2d Cir. 1985); Biermann v. Commissioner, 769 F.2d 707, 708
(11th Cir. 1985); Waters v. Commissioner, 764 F.2d 1389, 1389
(11th Cir. 1985); Perkins v. Commissioner, 746 F.2d 1187, 1188
(6th Cir. 1984), affg. T.C. Memo. 1983-474; Knighten v.
Commissioner, 702 F.2d 59, 60 (5th Cir. 1983); Funk v.
Commissioner, 687 F.2d 264, 264 (8th Cir. 1982), affg. T.C. Memo.
1981-506.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011