Homer W. and Nancy L. Winans - Page 3

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               In 2000, petitioner received wages of $57,123.30 from                  
          KForce.com, Inc., in Tampa, Florida, and Mrs. Winans received               
          wages of $25,540.96 from Flagler Hospital in St. Augustine,                 
          Florida.  Petitioner received wages of $86,743, $80,645, $57,019,           
          and $66,314 during the years 2001, 2002, 2003, and 2004,                    
          respectively.  Mrs. Winans received annual wages of about $30,000           
          during 2001-2004.                                                           
          B.   Petitioners’ Income Tax Returns and Respondent’s Notices of            
               Petitioners filed Forms 1040, U.S. Individual Income Tax               
          Return, for 1996-2001 in which they entered zeros for income,               
          tax, and amount owed.  Petitioners attached to their Forms 1040             
          written statements consisting solely of tax-protestor rhetoric,             
          including:  (1) No section of the Internal Revenue Code makes               
          them liable for income tax or requires that income taxes be paid            
          on the basis of a return; (2) the Privacy Act Notice indicates              
          that petitioners are not required to file income tax returns; (3)           
          no statute allows respondent to change petitioners’ return; and             
          (4) the word “income” is not defined in the Internal Revenue Code           
          and only applies to corporate activity.                                     
               In a letter to petitioners dated January 16, 2002,                     
          respondent stated that their return for 2000 was frivolous and              
          that they should seek advice from competent tax counsel.                    
          Respondent told petitioners the legal requirements for filing a             

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