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deficiency for 1995 determined in the notice of deficiency. We
also sustained the additions to tax.
The Court based our holding on “the invalidity of the
taxpayer’s arguments with regard to the nontaxability of the
income received from * * * his air-conditioning and heating
business.” The Court further noted: “The evidence is also clear
and overwhelming that the taxpayer has somehow bought on to some
tax protester scheme.”
We concluded by stating: “hopefully, he [petitioner] will be
anxious to pay his full share of taxes in the years ahead, and
file his returns timely and avoid the situation he’s currently
in.”
Petitioner’s Current Tax Court Case
During 2001, petitioner was married to Martha Leggett.
Petitioner failed to file Federal income tax returns for 1997,
1998, 1999, 2000, and 2001.
In 2001, petitioner received Social Security benefits of
$14,208. In 2001, petitioner received $4,010 from Maronda Homes,
Inc. (Maronda), and $5,890 from Rain-Tile Roofing, Inc. (Rain-
Tile), in exchange for personal services rendered.
OPINION
I. Deficiencies
Generally, respondent’s deficiency determinations set forth
in the notices of deficiency are presumed correct, and petitioner
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