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Commissioner, 751 F.2d 85, 87 (2d Cir. 1984) (holding that an
unapportioned income tax on wages is constitutional). A tax
return is not a prerequisite of a valid notice of deficiency.
See Schiff v. United States, 919 F.2d 830, 832 (2d Cir. 1990);
Roat v. Commissioner, 847 F.2d 1379, 1381-1382, 1384 (9th Cir.
1988) (denying Government’s request for sanctions, but warning
that the rejected arguments “have no place in this court.”);
Hartman v. Commissioner, 65 T.C. 542, 546 (1975). Petitioner's
other arguments are equally frivolous and without merit. All of
petitioner’s legal arguments are rejected as without merit.
F. Conclusion
Respondent’s determinations of deficiencies are sustained in
full.
II. Additions to Tax
A. Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failure to
file a timely return, unless it is shown that such failure is due
to reasonable cause and not due to willful neglect. Petitioner
bears the burden of proof as to reasonable cause and the absence
of willful neglect. See Rule 142(a).
Petitioner has conceded that she consciously decided not to
file returns for the taxable years in issue. Petitioner only
offers unreasonable tax-protester arguments to justify her
failure to file. Petitioner has not carried her burden of proof.
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