Alan D. Stang - Page 4

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          exemption from Federal income tax withholding; a document                   
          entitled “AFFIDAVIT OF CITIZENSHIP AND DOMICILE”; and a document            
          entitled “AFFIDAVIT OF CLAIMS FOR EXEMPTION AND EXCLUSION FROM              
          GROSS INCOME OF REMUNERATION, WAGES AND WITHHOLDING”.  The                  
          affidavits enumerated a litany of typical tax-protester                     
          assertions, including that the Internal Revenue Code was Federal            
          legislation inapplicable to him as a citizen of one of the 50               
          States and therefore not within the territorial jurisdiction of             
          the United States, that wages and remuneration for labor were               
          property not subject to indirect taxation, and that the income              
          tax was voluntary.                                                          
               During 1999, petitioner received $31,0272 in wages from GCE,           
          from which no Federal income tax was withheld.  GCE issued to               
          petitioner and filed with the Internal Revenue Service (IRS) a              
          Form W-2, Wage and Tax Statement, reflecting these wages.  During           
          2000, petitioner received total compensation of $60,930 from GCE,           
          comprising $32,054 in wages for which a Form W-2 was issued and             
          $28,876 in nonemployee compensation for which a Form 1099-MISC,             
          Miscellaneous Income, was issued.3  No Federal income tax was               


               2 For consistency with the notices of deficiency and the               
          deemed stipulation of facts, the monetary amounts of the                    
          compensation received by petitioner have been rounded to the                
          nearest dollar.                                                             
               3 It appears from the record that, on or about June 5, 2000,           
          GCE treated petitioner’s employment status as having changed from           
          that of an employee to that of an independent contractor.                   





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