4
tax. For example, petitioner contends that he is not liable for
income tax because he is a citizen of Georgia and not of the
United States. He claims that respondent lacks delegated
authority to collect tax and that the Internal Revenue Code lacks
"positive law" as its foundation. He also contends that he is
exempt from income tax because taxable gross income does not
include compensation for services. Petitioner's contentions are
merely a rehash of frivolous tax protester arguments which have
been uniformly rejected by this and other courts. Abrams v.
Commissioner, 82 T.C. 403, 406-407 (1984); Rowlee v.
Commissioner, 80 T.C. 1111 (1983); McCoy v. Commissioner, 76 T.C.
1027 (1981), affd. 696 F.2d 1234 (9th Cir. 1983). We see no need
to catalog petitioner's contentions and painstakingly address
them. See, e.g., Crain v. Commissioner, 737 F.2d 1417 (5th Cir.
1984); Solomon v. Commissioner, T.C. Memo. 1993-509, affd.
without published opinion 42 F.3d 1391 (7th Cir. 1994).
B. Unreported Income
Respondent determined that petitioner failed to report
nonemployee compensation income paid to him by MAP of $119,492 in
1992 and $106,695 in 1993. Respondent's determination is
presumed to be correct, and petitioner bears the burden of
proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S.
111, 115 (1933).
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