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time the return was due, he believed he was not required to file
tax returns or pay taxes because money he received for his labor
was a nontaxable exchange of equal value.1 Petitioner, however,
did timely file a tax return for taxable year 2001. Based on a
Form 1099 issued to petitioner by Lauren’s Cycle Sales, Inc. for
taxable year 2000, respondent determined a $9,378 deficiency in
tax and additions to tax pursuant to sections 6651(a)(1) and
6654(a) in the amounts of $2,3452 and $504.39, respectively, and
sent petitioner a notice of deficiency on April 7, 2004.
Respondent computed the deficiency using the tax rates under
section 1(c) for an unmarried individual who is not a head of
household. Petitioner timely petitioned this Court contending:
“I do not have any tax liability. I deny the figures and content
of the Notice of Deficiency. I dispute the computations. In the
year in question I had dependents, deductions, credits, business
expenses, etc. Local taxes, interest, dependent son.”
1We note that petitioner has previously appeared before this
Court. In docket No. 19512-03L, a case in which we entered oral
findings of fact and opinion pursuant to sec. 7459 and Rule 152,
petitioner contended, among other frivolous contentions, that he
did not owe taxes for taxable year 1993 because respondent sent
the notice of determination to a “straw man” when respondent used
all capital letters to spell petitioner’s name. Petitioner
subsequently had a change of heart regarding the tax laws and
started filing returns, beginning with taxable year 2001.
2The addition to tax pursuant to sec. 6651(a)(1) determined
in the notice of deficiency was originally, and incorrectly,
calculated as $3,704.31.
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