Richard A. Paikowski - Page 5

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          return “‘which does not contain any information relating to the             
          taxpayer’s income from which the tax may be computed is not a               
          return within the meaning of the Internal Revenue Code.’”  United           
          States v. Moore, 627 F.2d 830, 834 (7th Cir. 1980) (quoting                 
          United States v. Porth, 426 F.2d 519, 523 (10th Cir. 1970));                
          Sloan v. Commissioner, 102 T.C. 137, 142 (1994).  The taxpayer              
          must have an honest and reasonable intent to supply the                     
          information required by the tax code for a form to constitute a             
          return.  United States v. Moore, supra at 835.                              
               Petitioner, by entering zeros on all lines on the income               
          portion of his returns, did not have an honest and reasonable               
          intent to supply the information required.  Therefore, the forms            
          submitted by petitioner for 1999 and 2002 do not constitute                 
          Federal income tax returns.                                                 
               Section 61(a)(1) provides that “gross income means all                 
          income from whatever source derived”, including “Compensation for           
          services”.  See Cent. Ill. Pub. Serv. Co. v. United States, 435             
          U.S. 21, 25 (1978); United States v. Basye, 410 U.S. 441, 449               
          (1973).  Petitioner does not dispute that he earned wages for               
          1999 and 2002 and that the wages represented compensation for               
          services rendered.  See Cabirac v. Commissioner, supra at 167               
          (“It is beyond contention that wages represent taxable income”).            
          It is a general tax law principle that “full compensation for               
          services rendered--no matter to whom paid, or when--is income               






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