Jerome V. Mancebo - Page 4

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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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