Shirley S. Hirsh - Page 6

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          (3) Acts of Congress have no force over citizens of the various             
          States, except for Federal citizens and employees, unless there             
          are regulations published in the Federal Register; (4) the                  
          Internal Revenue Code only applies to "import duties on alcohol,            
          tobacco and firearms"; (5) the Supreme Court is the sole court              
          which may adjudicate this controversy since it is exclusively               
          endowed with Article III authority; and (6) respondent's agents             
          have no authority or jurisdiction over the citizens of the                  
          various States; thus, those agents do not have immunity from                
          their purportedly illegal acts.                                             
               The above arguments are without legal and factual                      
          foundation, and are without merit.  Petitioner's argument that              
          she is not a taxpayer is patently frivolous.  United States v.              
          Studley, 783 F.2d 934, 937 (9th Cir. 1986).2  We have generally             
          recognized that petitions containing frivolous arguments add to             
          the Court's case load and cause needless expenditures of time,              
          effort, and expense by the Commissioner and by this Court.                  
          Hatfield v. Commissioner, 68 T.C. 895, 899 (1977).  We are not              
          obligated to review exhaustively and rebut petitioner's misguided           



               2 "We note that this argument has been consistently and                
          thoroughly rejected by every branch of the government for                   
          decades.  Indeed advancement of such utterly meritless arguments            
          is now the basis for serious sanctions imposed on civil litigants           
          who raise them."  United States v. Studley, 783 F.2d 934, 937               
          n.3.                                                                        




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