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similar arguments the Court of Appeals for the Fifth Circuit
opined: "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."
This Court and the Court of Appeals for the Ninth Circuit
have held petitioner's arguments to be nothing more than tax
protester rhetoric and legalistic gibberish. See Fuller v.
United States, 786 F.2d 1437 (9th Cir. 1986); Hudson v. United
States, 766 F.2d 1288 (9th Cir. 1985); United States v. Romero,
640 F.2d 1014 (9th Cir. 1981); Woods v. Commissioner, 91 T.C. 88
(1988); Abrams v. Commissioner, 82 T.C. 403 (1984); Rowlee v.
Commissioner, 80 T.C. 1111 (1983); McCoy v. Commissioner, 76 T.C.
1027 (1981), affd. 696 F.2d 1234 (9th Cir. 1983); Snyder v.
Commissioner, T.C. Memo. 1995-405; Devon v. Commissioner, T.C.
Memo. 1995-206; McGanty v. Commissioner, T.C. Memo. 1995-178;
Diehl v. Commissioner, T.C. Memo. 1990-48.
Petitioner contends that the tax liability for the taxable
year in issue is uncollectible because respondent failed to make
an assessment within 3 years. However, pursuant to section
6501(c)(3), in the case of the failure to file a return, the tax
may be assessed or a proceeding in court for the collection of
such tax may be begun without assessment at any time.
Section 6651(a)(1) imposes an addition to tax for failure to
timely file a return, unless the taxpayer establishes: (1) The
failure did not result from "willful neglect"; and (2) the
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