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issued to Terry in 2001 reflecting nonemployee compensation of
$8,812.72. The declaration of Deborah S. Kerns, a paralegal
analyst employee at Principal Life Insurance Company, was offered
into evidence. Attached to Ms. Kerns’s declaration was a copy of
a Form 1099-INT issued to Louise for interest paid to her in 2001
in the amount of $343.58. Respondent also sought to admit into
evidence the declaration of Marlene Mills, an employee of Mellon,
and the attached Form 1099-B issued to Louise in 2001 for
demutualization compensation received in the form of cash in the
amount of $18,037.50. The Court admitted these declarations into
evidence despite Terry’s objections.
OPINION
I. Contentions of the Parties
Petitioners contended that they were not required to file a
Federal income tax return for the taxable year 2001.
Specifically, they argued that they did not receive any amounts
that constitute gross income and asserted that respondent’s
evidentiary documents were inadmissible. Petitioners raised tax
protester arguments in opposition to the constitutionality of the
filing requirement of section 6011.
Respondent claimed that petitioners earned income in the
form of compensation and interest for 2001. Since petitioners
did not provide any evidence or documentation to contradict
respondent’s evidence, respondent contended that the
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