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fact in support of any justiciable claim. Rather, there is nothing other than
a terse statement of tax protester rhetoric. See Abrams v. Commissioner, 82
T.C. 403 (1984); Rowlee v. Commissioner, 80 T.C. 1111 (1983); McCoy v.
Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d 1234 (9th Cir. 1983).
The Court's order dated July 18, 1995, provided petitioner with an
opportunity to assign error and allege specific facts concerning his liability
for the taxable years in issue. Unfortunately, petitioner failed to respond
properly to the Court's order. Rather, petitioner elected to continue to
proceed with time-worn tax protester rhetoric, expanding upon the gibberish in
his petition. See Abrams v. Commissioner, supra; Rowlee v. Commissioner,
supra; McCoy v. Commissioner, supra; Karlin v. Commissioner, T.C. Memo. 1990-
496.
We see no need to painstakingly address petitioner's arguments. The
short answer to them is that petitioner is not exempt from Federal income tax
or from the imposition of appropriate additions to tax. See Abrams v.
Commissioner, supra at 406-407. Moreover, as the Court of Appeals for the
Fifth Circuit has remarked: "We perceive no need to refute these arguments
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).
Because neither the petition nor the amended petition states a claim
upon which relief can be granted, we will grant respondent's motion to dismiss
for failure to state a claim. See Scherping v. Commissioner, 747 F.2d 478
(8th Cir. 1984); see also Nieman v. Commissioner, T.C. Memo. 1993-533; Solomon
v. Commissioner, T.C. Memo. 1993-509, affd. without published opinion 42 F.3d
1391 (7th Cir. 1994).
We turn now on our own motion, to the award of a penalty against
petitioner under section 6673(a).
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