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the years 1996 and 1997 was responsible for paying the respective
unpaid income tax liabilities for those years. The Court re-
jected that argument. According to the Court,
The obvious fallacy in petitioners’ reasoning is that
the income tax is petitioners’ obligation in the first
instance. An employer, on the other hand, is an inter-
mediary or collection agent who may be obligated to
withhold amounts from an employee for the employee’s
future use as a credit or payment of any income tax
liability. Whether Mr. Anderson was self-employed or
instead was an employee of the boat owners, the fact
remains that nothing was withheld from what they paid
him. Thus his gross receipts from that source are
subject to income tax in their entirety, with no credit
for withholding. * * *
* * * Petitioners’ arguments are without substance and
constitute nothing more than mere protester type argu-
ments, which are not worthy of further analysis or
review.
Accordingly, we hold that petitioners are liable for
the income tax, as reported by them, for 1996 and 1997.
Id.
Ms. Latos did not receive a notice of deficiency with
respect to her taxable years 1996 and 1997. However, in Anderson
v. Commissioner, supra, Ms. Latos and Mr. Anderson had the
opportunity to dispute the underlying tax liability for each of
those years, and they did so, albeit unsuccessfully. On the
record before us, we conclude that Ms. Latos may not challenge
Ms. Latos’ unpaid 1996 liability or Ms. Latos’ unpaid 1997
liability.17
17Assuming arguendo that we had concluded that Ms. Latos is
(continued...)
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