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for 1999. Petitioner did not report any taxes paid or withheld
for 1999, and he reported zero tax liability for the year.
Petitioner attached copies of (1) a Form W-2 for 1999 from
Watson, Inc., reporting the payment of $10,000 in wages to
petitioner and zero Federal income tax withheld, (2) a Form 1099-
MISC, Miscellaneous Income, for 1999 from Watson, Inc., reporting
the payment of $4,400 to petitioner, and (3) a Form 1099-R for
1999 from Mobil Pension Trust reporting a $3,342.12 distribution
to petitioner, the amount he (mistakenly) reported on line 20b of
the 1999 Form 1040. Petitioner signed the 1999 Form 1040 under
the jurat and, as on the 1998 Form 1040, he wrote immediately
above his signature: “Under Protest Without Prejudice”. On line
7 of the 1999 Form 1040 he wrote “SEE Attached”. In addition,
along the length of the left margin of both pages of the 1999
Form 1040 and the page containing copies of the above referenced
Forms W-2 and 1099, petitioner inserted the following statement:
This tax return is being filed under protest, without
prejudice, see the attached 48 page protest document
and memorandum, marked and identified by its U.S.
registered mail number. It is a federal crime under
Title 18 U.S.C., to remove this protest document from
the attached tax return, it is to remain a permanent
part of the records with the return.
On page 1 of the 48 page protest referred to in the above
statement, petitioner states:
All items of alleged income have been reported, even
though the undersigned disagrees with the instructions
of [sic] the IRS information. This is only done as a
precaution, as to avoid criminal prosecution under 26
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