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right of Indian tribes to self-government and support tribal
sovereignty and self-determination. The consultation requirement
in Executive Order 13175 provides that “Each agency shall have an
accountable process to ensure meaningful and timely input by
tribal officials in the development of regulatory policies that
have tribal implications.” Id. at 67250. Executive Order 13175
does not revoke or supersede any statute or regulation.
OPINION
Wages and Unemployment Compensation
Section 1 imposes a tax on all taxable income. Section
61(a)(1) includes in gross income “all income from whatever
source derived”, including compensation for services. Respondent
thus determined that the amounts paid to petitioner by Ridley and
his unemployment compensation were taxable income. Petitioner
contends that he is not a U.S. citizen, but rather an “Indian not
paying taxes”. Citing a number of treaties and statutes, he
argues that his compensation is exempt from tax because he is an
“Onondaga and as such entitled to the exemption”. Petitioner has
used similar arguments in the past, and the Court has previously
found that he is not exempt from taxation on his income. George
v. Commissioner, T.C. Memo. 1989-401.
Native Americans are subject to the same Federal income tax
laws as are other U.S. citizens, unless there is an exemption
explicitly created by treaty or statute. Squire v. Capoeman, 351
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