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taxes for the Utah Republic, and that the United States is not a
governmental entity. The argument of petitioner, whatever the
rationale, is nonsensical. Petitioner presented no evidence at
trial to refute the determinations in the notice of deficiency.
To the contrary, petitioner admitted receiving the amounts
characterized as taxable income in the notice of deficiency. The
determinations of the Commissioner in a notice of deficiency are
presumed correct, and the taxpayer bears the burden of proving
that the determinations are in error. Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933).
Petitioner's case is frivolous. All taxpayers with taxable
income are generally required by law to file Federal income tax
returns. Sec. 6012. Under sections 6651 and 7203, taxpayers who
fail to file income tax returns may be subject to civil additions
to the tax and prosecution for criminal offenses. Moreover,
under section 6673(a), this Court may award a penalty in favor of
the United States if any proceeding has been instituted or
maintained in this Court for frivolous reasons or for purposes of
delay. A valid notice of deficiency was issued by respondent to
petitioner pursuant to section 6212. The Court finds no need to
address the frivolous and nonsensical allegations and contentions
of petitioner. To do so might suggest that petitioner's
arguments have some colorable merit, which they do not. See
Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984). Very
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