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The arguments made by petitioners are without factual and
legal foundation and appear to represent a protest of the Federal
tax laws. These types of tax protester arguments have been heard
by this Court on many occasions and rejected. We see no need to
respond to each of petitioners' arguments with copious citations
of precedent. See Crain v. Commissioner, 737 F.2d 1417 (5th Cir.
1984). In short, petitioners are taxpayers subject to the income
tax laws. See Abrams v. Commissioner, 82 T.C. 403, 406-407
(1984). Petitioners' argument that they are not taxpayers is
frivolous. United States v. Studley, 783 F.2d 934, 937 (9th Cir.
1986).
Gross income, pursuant to section 61, means all income from
whatever source derived and includes income realized in any form,
whether in money, property, or services. Since petitioners were
citizens and residents of the United States and earned their
income in the United States, their income comes within the
general definition of gross income under section 61. Moreover,
under section 7701(a)(1) petitioners were "persons" and were
required, under section 6012, to file Federal income tax returns,
and pay the income tax due thereon. The authority of Congress to
impose and collect Federal income taxes from individuals has long
been upheld as constitutional. James v. United States, 366 U.S.
213 (1961); O'Malley v. Woodrough, 307 U.S. 277 (1939); Lynch v.
Hornby, 247 U.S. 339 (1918).
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