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Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d 1234 (9th Cir.
1983); see also Fox v. Commissioner, T.C. Memo. 1993-37; Fox v.
Commissioner, T.C. Memo. 1989-232, affd. without published
opinion 943 F.2d 55 (9th Cir. 1991). Aside from the Coram
Taxvest Windfarms issues that the parties settled, petitioner has
failed to allege any triable issue of fact.
We see no need to catalog petitioner's contentions and
painstakingly address them. We have dealt with many of them
before. E.g., Nieman v. Commissioner, T.C. Memo. 1993-533;
Solomon v. Commissioner, T.C. Memo. 1993-509, affd. without
published opinion 42 F.3d 1391 (7th Cir. 1994). Further, as the
Court of Appeals for the Fifth Circuit has remarked: "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." Crain v.
Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984). Suffice it to
say that petitioner's motions for summary judgment are wholly
without merit and will be denied.
Respondent's Motions for Summary Judgment
As previously mentioned, the first four issues on which
respondent seeks summary judgment are that petitioner (1) failed
to report interest and dividend income on his 1983, 1984, and
1985 tax returns, (2) is not entitled to a loss of $3,880
reported on Schedule C attached to his 1983 tax return, (3) is
not entitled to a loss in the amount of $2,410 claimed on his
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