- 6 - capital value of labor is equal to the value of wages and therefore wages do not constitute income or create a zero gain. We warned petitioner at calendar call in Columbia, Tennessee (Nashville session) and also during trial that, if he continued to raise the type of arguments he was advancing, he was at risk of having a penalty under section 6673 imposed. He persisted in advancing these arguments at trial. The Court again warned petitioner in a written order dated June 7, 2005, regarding additional submissions petitioner sent the Court after trial. OPINION Petitioner raises the same issues here as he did in docket No. 7178-03 regarding 2000 on whether what he filed constituted a valid return, whether the pension distributions and Social Security benefits he received were taxable, and whether he is liable for the estimated tax addition. We issued an opinion on July 19, 2005, in which we discussed in length all these issues and petitioner’s arguments. Lange v. Commissioner, T.C. Memo. 2005-176. Because these issues in Lange are the same here, our holdings on these issues apply here. Take v. Commissioner, T.C. Memo. 1985-388 (holding in a prior opinion on the same issue applies to the later year); Frazier v. Commissioner, T.C. Memo. 1979-515 (same), affd. 638 F.2d 63 (8th Cir. 1981). We briefly discuss these issues. There are two additional issues we must also determine here that were not raised in Lange. First, we must decide whether petitioner may claim itemized deductions if his wife filed aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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