Ed M. Fisher - Page 6

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          this Court and all other courts that have heard such contentions.           
          Rowlee v. Commissioner, supra.  Petitioner is a taxpayer and is             
          subject to the income tax laws of the United States.  United                
          States v. Sloan, 939 F.2d 499, 501 (7th Cir. 1991); Lovell v.               
          United States, 755 F.2d 517, 519 (7th Cir. 1984).  The Court                
          rejects this and other tax protester types of arguments raised by           
          petitioner as being frivolous and without merit.                            
               Petitioner has the burden of proof with respect to the                 
          underlying deficiencies and each of the additions to tax.  Rule             
          142(a); Shomaker v. Commissioner, 38 T.C. 192, 202 (1962).  Peti-           
          tioner has not presented any evidence rebutting his liability for           
          the deficiencies and additions to tax determined by respondent.             
          We therefore sustain all of respondent's determinations.                    
               At the trial, respondent made a motion under section 6673(a)           
          asking that we order petitioner to pay the United States a                  
          penalty in an appropriate amount.  Under section 6673, this Court           
          is permitted to impose a penalty in an amount up to $25,000 where           
          the proceedings have been instituted or maintained by the                   
          taxpayer primarily for delay, where the taxpayer's position in              
          the proceeding is frivolous or groundless, or where the taxpayer            
          unreasonably failed to pursue available administrative remedies.            
          Grimes v. Commissioner, 82 T.C. 235, 238 (1984).                            
               The record plainly demonstrates that petitioner well knew              
          that his income was taxable.  His arguments have been rejected in           
          many decisions by this Court in the recent past.  We conclude               

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