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OPINION
Petitioner sought the jurisdiction of this Court by means of
a petition alleging that respondent had erred in determining
income tax deficiencies for petitioner's 1993 and 1994 taxable
years. Petitioner refused to show his records to respondent's
agents, and he also refused respondent's offer to stipulate
facts. Petitioner stated that he appeared at trial for the
purpose of expressing the view that the burden of proof should
not be on taxpayers, but instead should be on respondent. The
Court explained to petitioner that the rules were well-
established that he had to bear the burden of showing that
respondent's determination was in error. See Rule 142(a); Welch
v. Helvering, 290 U.S. 111 (1933). It was also explained to
petitioner that if he did not come forward with any evidence, the
Court would have no choice other than to sustain respondent's
determination. Petitioner stated that he was willing to bear a
tax burden for which he otherwise may not have been obligated in
order to make the point that the tax system, as statutorily
configured, is unfair.
Petitioner proceeded, under oath, to testify. Petitioner's
relatively brief testimony mainly addressed his disagreement with
the current approach to Federal tax administration and the
resolution of Federal tax controversies. Within those comments,
however, petitioner stated that he had some income, but that the
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Last modified: May 25, 2011