Timothy Harvey - Page 11

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          to pay estimated tax.  Despite the Court's holding for the tax              
          years 1991 and 1992 (in an opinion served on the parties on                 
          February 8, 1996), petitioner filed a petition in the instant               
          case on March 25, 1996, making many of the same claims as he did            
          in the earlier case.                                                        
               This Court and other Federal courts have consistently and              
          uniformly held for many years that compensation is income.  E.g.,           
          Beard v. Commissioner, 793 F.2d 139 (6th Cir. 1986), affg. per              
          curiam 82 T.C. 766 (1984); Coleman v. Commissioner, 791 F.2d 68,            
          70 (7th Cir. 1986); Carter v. Commissioner, 784 F.2d 1006, 1009             
          (9th Cir. 1986); Olson v. United States, 760 F.2d 1003, 1005 (9th           
          Cir. 1985); United States v. Burton, 737 F.2d 439, 441 (5th Cir.            
          1984); Gattuso v. Pecorella, 733 F.2d 709, 710 (9th Cir. 1984);             
          Funk v. Commissioner, 687 F.2d 264, 265 (8th Cir. 1982), affg.              
          T.C. Memo. 1981-506; Lonsdale v. Commissioner, 661 F.2d 71, 72              
          (5th Cir. 1981), affg. T.C. Memo. 1981-122; United States v.                
          Romero, 640 F.2d 1014, 1016 (9th Cir. 1981).                                
               Petitioner's arguments are basic tax protester rhetoric.  As           
          the Court of Appeals for the Fifth Circuit has 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, 1417 (5th Cir. 1984).                          
               The record in this case convinces us that petitioner was not           
          interested in disputing the merits of either the deficiencies in            




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