Craig A. Bratcher - Page 11

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          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 deficiency                        






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