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petitioner's trial memorandum, he persists in advancing the same
and/or similar tax protester type arguments. We reaffirm our
earlier finding that the types of arguments that petitioner is
advancing in this case have been consistently rejected by us and
other courts, and we find those arguments to be frivolous and
groundless.
On the record before us, we find that petitioner received
compensation income for services rendered during 1991 in the
total amount of $43,403.05. We further find on that record that
petitioner failed to show error in respondent's determinations in
the notice that for 1991 he (1) had interest income in the amount
of $14 and (2) is liable (a) for self-employment tax, (b) the
addition to tax under section 6651(a)(1), and (c) the addition to
tax under section 6654 in the revised amounts computed by respon-
dent to reflect her concession relating to the incorrect Form
1099 issued to petitioner by Codega & Fricke.
In respondent's trial memorandum, respondent requests the
Court to impose a penalty on petitioner under section 6673.4 We
have consistently applied section 6673 in cases where, as here,
it is clear that the taxpayer's position in the proceeding before
4 Respondent made the same request in respondent's motion.
Since we found that petitioner had alleged in his amended
petition one justiciable error of fact in respondent's
determinations relating to the Form 1099 issued by Codega &
Fricke in the amount of $6,791.10, we did not grant that motion
and therefore did not award a penalty under sec. 6673.
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