- 11 -
Commissioner, supra; Rowlee v. Commissioner, supra; McCoy v.
Commissioner, supra; Karlin v. Commissioner, T.C. Memo. 1990-496.
We see no need to catalog petitioner's arguments regarding
section 83, or section 7701(e) for that matter, and painstakingly
address them. 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 (5th Cir. 1984).
Petitioner's arguments are nothing other than a variation on the
theme that wages are not income. Suffice it to say that both
this and other Federal courts have consistently and uniformly
held for many years that wages are income and that a taxpayer has
no basis in his or her labor. E.g., Beard v. Commissioner, 793
F.2d 139 (6th Cir. 1986), affg. per curiam 82 T.C. 766 (1984);
Coleman v. Commissioner, 791 F.2d 68, 70 (7th Cir. 1986); Carter
v. Commissioner, 784 F.2d 1006, 1009 (9th Cir. 1986); Olson v.
United States, 760 F.2d 1003, 1005 (9th Cir. 1985); United States
v. Burton, 737 F.2d 439, 441 (5th Cir. 1984); Gattuso v.
Pecorella, 733 F.2d 709, 710 (9th Cir. 1984); Funk v.
Commissioner, 687 F.2d 264, 265 (8th Cir. 1982), affg. T.C. Memo.
1981-506; Lonsdale v. Commissioner, 661 F.2d 71, 72 (5th Cir.
1981), affg. T.C. Memo. 1981-122; United States v. Romero, 640
F.2d 1014, 1016 (9th Cir. 1981) ("Compensation for labor or
services, paid in the form of wages or salary, has been
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