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base year income, respondent determined that petitioner earned
net profits of $77,401, $79,718, and $81,759 from his
chiropractic business during the taxable years 1992, 1993, and
1994, respectively.
Petitioner invoked this Court's jurisdiction by filing a
timely petition for redetermination on September 18, 1995.3 The
petition states in pertinent part:
1. Petitioner specifically denies the receipt of the
taxable income shown in the "Notice of Deficiency" on
which the amount of the alleged deficiency was figured,
and, therefore, denies the deficiency and the penalties
because of the inaccuracies in that taxable income,
and,
2. Petitioner pleads that there is/are no implementing
regulations of the Code of Federal Regulations which
give any authority to the Internal Revenue Service, or
any of its officers or employees, to proceed in the
manner in which it has proceeded in the instant matter,
and, therefore, the actions taken by the Internal
Revenue Service in this matter falls outside of its
scope of authority granted to it by the code, and,
3. Petitioner pleads that, based upon Title 26 USC (The
Internal Revenue Code) and its implementing
regulations, Petitioner is engaged in no taxable
activities, and is therefore outside the jurisdiction
of the Internal Revenue Service, and,
4. Petitioner pleads that the burden of proving the
non-receipt of income is beyond the reasonable burden
which the Court should place on an individual, and
5. Petitioner pleads that the entire case by the
Government is based upon a "naked assertion", i.e. one
person's word against another's, and therefore is
insufficient to sustain a decision in the Government's
favor.
3 At the time he filed his petition, petitioner was
residing in Longview, Texas.
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