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Commissioner, 73 T.C. 736, 739 (1980). Further, the failure of a
party to plead or otherwise proceed as provided in the Court's
Rules may be grounds for the Court to hold such party in default
either on the motion of another party or on the initiative of the
Court. Rule 123(a).
Based upon our review of the petition, petitioner's motion,
and Rule 50(c) statement, we conclude that petitioner has failed
to satisfy the requirements of Rule 34(b). Viewing the petition
in isolation, the best that can be said is that petitioner has
assigned error in respect of respondent's determinations.
However, the petition lacks any statement of the facts on which
petitioner bases the assignments of error. Petitioner's Motion
to Shift the Burden of Proof to Respondent adds nothing in this
regard. Petitioner's Rule 50(c) statement contains significant
admissions. Rather than denying that he was engaged in an
income-producing activity during the years in issue, petitioner
admits that he received compensation from operating a
chiropractic business. Petitioner also concedes that he
maintained income-producing investments during the period in
question. In conjunction with these statements, petitioner
asserts that respondent erred in determining deficiencies in this
case on the theories that (1) compensation received in exchange
for labor is not taxable income, and (2) as a sovereign citizen,
he is not subject to the Federal income tax.
Petitioner's arguments are nothing more than time-worn tax
protester arguments that have been long rejected by this and
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