Edward J. Frami - Page 8

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          issue.  In addition, at trial, respondent's agent confirmed that            
          petitioner was not under criminal investigation by the IRS.                 
               Likewise, we find petitioner's attempt to justify legally              
          his position that he is not subject to Federal income tax to be a           
          repeat of concepts which have been soundly rejected by the                  
          Courts.  In a terse statement attached to his delinquent 1993               
          return, petitioner espoused several well-worn, protester-type               
          arguments why he should not be liable for Federal income tax.  He           
          attempted to support those arguments by reference to statutes,              
          regulations, and cases which are only related to each other                 
          because they all involve issues of taxation.  Petitioner by                 
          piecing together otherwise unconnected concepts into a patchwork            
          designed to suit his purpose of avoiding his tax obligations has            
          relied on material that is without direct relevance or substance.           
               Petitioner's legal arguments are without merit and lack                
          factual and legal foundation.  In that regard, we are not                   
          obligated to exhaustively review and rebut petitioner's misguided           
          contentions.  Crain v. Commissioner, 737 F.2d 1417, 1417 (5th               
          Cir. 1984) ("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.");            
          accord Casper v. Commissioner, 805 F.2d 902 (10th Cir. 1986),               
          affg. T.C. Memo. 1985-154.                                                  







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