- 23 - “Denial and disclaimer makes unclear whether petitioner had an ‘honest and reasonable intent to supply the information required by the tax code.’” In Lange v. Commissioner, T.C. Memo. 2005-176, the taxpayer attached a cover letter to the front of his Form 1040, which contained a statement that was virtually identical to the statement inserted into the margin on each page of petitioner’s 1999 Form 1040. The taxpayer in Lange also attached a “protest document” to his Form 1040, which contained many of the arguments made in the protest document attached to petitioner’s 1999 Form 1040: E.g., he is not an individual as that term is used in sections 1 and 3, private sector employees should not be taxed at the same rate as Government employees, and only Government employment is subject to taxation. In Lange, we determined that such arguments are frivolous and that the taxpayer’s Form 1040 did not “represent an honest and reasonable attempt to satisfy the requirements of the tax law” thereby failing to satisfy part 3 of the four-part test under Beard v. Commissioner, 82 T.C. 166 (1984), affd. 793 F.2d 139 (6th Cir. 1986). The attachment to the 1998 Form 1040 is different from the attachment to the 1999 Form 1040. Principally, it constitutes an argument that petitioner, a self-proclaimed “private independent contractor”, received no income subject to employment taxes from his employer, Watson, Inc. As part of that attachment, in thePage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: November 10, 2007