- 11 - 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 November 27, 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 to the Court's order in a meaningful fashion. We see no need to catalog petitioner's arguments 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, 1417 (5th Cir. 1984). Suffice it to say that petitioner is not exempt from Federal income tax or from the obligation to file income tax returns. See sec. 6012(a)(1); Abrams v. Commissioner, supra at 406-407. Moreover, the contention that the Commissioner cannot determine a deficiency because the taxpayer has not filed an income tax return is frivolous. Zyglis v. Commissioner, T.C. Memo. 1993-341, affd. without published opinion 29 F.3d 620 (2d Cir. 1994); Scruggs v. Commissioner, T.C. Memo. 1995-355; Roman v. Commissioner, T.C. Memo. 1995-175. We also think it appropriate to comment briefly on petitioner's allegation that respondent's deficiencyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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