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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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