Donald P. Arnett - Page 4

                                        - 4 -                                         
              Petitioner stipulated that he received the income listed on             
         the notice of deficiency.2  Petitioner contends, inter alia, that            
         the earnings he received are not income, and therefore he is not             
         liable for taxes.  Petitioner also argues that the statutory                 
         notice of deficiency he received is invalid because it was not               
         signed by the Secretary of the Treasury or an agent designated by            
         the Secretary.  Petitioner advanced these and other arguments in             
         filings and at the hearing.  These arguments are characteristic              
         of tax-protester rhetoric that has been universally rejected by              
         this and other courts.  Casper v. Commissioner, 805 F.2d 902                 
         (10th Cir. 1986), affg. T.C. Memo. 1985-154; Charczuk v.                     
         Commissioner, 771 F.2d 471 (10th Cir. 1985), affg. T.C. Memo.                
         1983-433; Michael v. Commissioner, T.C. Memo. 2003-26; Knelman v.            
         Commissioner, T.C. Memo. 2000-268, affd. without published                   
         opinion 33 Fed. Appx. 346 (9th Cir. 2002).  We shall not                     
         painstakingly address petitioner’s assertions “with somber                   
         reasoning and copious citation of precedent; to do so might                  
         suggest that these arguments have some colorable merit.”  Crain              
         v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).                        
              Accordingly, we conclude that petitioner is liable for the              
         deficiency determined by respondent.                                         



               2  Petitioner received payments totaling $35,873 from                  
          various sources including wages, unemployment compensation,                 
          income from self-employment, and IRA distributions.                         




Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011