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his taxable income, including gain realized on the sale of a
capital asset.
In general, the determinations made by the Commissioner in a
notice of deficiency are presumed to be correct, and the taxpayer
bears the burden of proving that those determinations are
erroneous. Rule 142(a); INDOPCO Inc., v. Commissioner, 503 U.S.
79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933).
There is no merit to petitioner's allegations that he is not
subject to Federal income taxes or to any other arguments offered
by petitioner. See, e.g., Rowlee v. Commissioner, 80 T.C. 1111
(1983); Carroll v. Commissioner, T.C. Memo. 1994-18; McDougall v.
Commissioner, T.C. Memo. 1992-683, affd. per curiam without
published opinion 15 F.3d 1087 (9th Cir. 1993). We see no need
to catalog and painstakingly address petitioner's contentions,
constitutional or otherwise. As the Court of Appeals for the
Fifth Circuit 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 (5th Cir.
1984).
The general rule of section 61(a) is that, except as
otherwise provided by law, gross income includes income from
whatever source derived, including, inter alia: (1) compensation
for services, section 61(a)(1); (2) gains derived from dealings
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