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It is readily apparent that petitioner had no intention to
dispute the fact that he had received from Mr. Langeliers in 1991
commissions in the amount of $94.62, a fact which he would not
admit. It is also readily apparent that petitioner attempted to
use Mr. Langliers as a foil on cross-examination to insinuate
into the record his cherished Exhibit 3 for identification, which
would allow him to expostulate upon the inanities contained
therein.
Respondent's determinations are presumed correct, and
petitioner bears the burden of proving otherwise. Rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933). Petitioner has
failed to prove that respondent's determination of his unreported
income for 1991 is incorrect. Indeed, as we have noted supra,
petitioner did not even attempt to prove that respondent's
determination was incorrect. We hold for respondent on this
issue.
We turn now to respondent's oral motion to award a penalty
against petitioner under section 6673(a). In order to better
understand our disposition of respondent's motion, we deem it
appropriate to place the issue in perspective.
In 1995, David Myrland (Myrland) authored a tax protester
diatribe--"CODE BREAKER - The � 83 Equation". The text of
Myrland's tirade consists of 62 pages.
On May 20, 1994, petitioner filed his "Petition Under 90 Day
Notice of Deficiency; Wage Earner, Contractor".
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