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arguments under the Fifth Amendment to the Constitution in
opposition to the filing requirement.
Respondent claims that petitioner received income in 1999
and 2000 from various sources. Respondent maintains that the
entities, National Land Bank and Speck, should be disregarded for
tax purposes due to each entity’s lack of economic substance.
Thus, the income from these entities should be attributed to
petitioner. Because petitioner did not pay taxes on self-
employment income, respondent maintains that petitioner is liable
for self-employment tax, and since petitioner did not
substantiate Miroyal’s or her deductions, respondent seeks to
disallow the claimed deductions.
II. Petitioner’s Fifth Amendment Claims
A person does not have a blanket Fifth Amendment privilege
to avoid filing a Federal income tax return or to refuse signing
a Federal income tax return under penalties of perjury. See
United States v. Sullivan, 274 U.S. 259, 263 (1927); see also
Major v. Commissioner, T.C. Memo. 2005-141 n.2; Brunner v.
Commissioner, T.C. Memo. 2004-187, affd. per curiam 142 Fed.
Appx. 53 (3d Cir. 2005). In order for an individual validly to
9(...continued)
under sec. 7430 would be premature, and the Court will not
further discuss the issue in this report. See Rule 231.
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