Thomas W. Minguske - Page 4

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                                       OPINION                                        
               Petitioner did not file an income tax return for either year           
          in issue, and respondent determined that petitioner was liable              
          for the above-mentioned deficiencies and additions thereto.                 
          Petitioner must prove respondent's determinations wrong.  Rule              
          142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).                       
               Petitioner has not introduced any evidence that rebuts the             
          evidence submitted in support of respondent's determination of              
          the income tax deficiencies and additions thereto.  Instead of              
          attempting to challenge the merits of respondent's                          
          determinations, petitioner chooses to rely on shopworn assertions           
          as to the validity of the Federal income tax system.  All of                
          petitioner's arguments are similar to rejected arguments of other           
          taxpayers who have previously petitioned this Court in protest of           
          their liability for Federal income tax.  Petitioner's assertions            
          in this case are characteristic of the tax-protester rhetoric               
          that has been universally rejected by this and other courts.  We            
          will not painstakingly address petitioner's assertions as to the            
          validity of the Federal income tax system "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).  Suffice it to           
          say that petitioner is subject to Federal income tax during the             
          relevant years, and we sustain respondent's determinations.                 





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