Roland Allen Pelletier - Page 5

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             petitioner sets forth his principal contention that the                  
             16th Amendment to the Constitution is "invalid and void."                
             Petitioner also sets forth therein a number of other                     
             contentions, such as "wages do not constitute 'Income'                   
             under the Constitution and laws", and "The Emancipation                  
             Proclamation of 1865 guarantees to every person the                      
             sanctity of his own labor."                                              
                  Shortly after receiving petitioner's trial memorandum,              
             the Court issued an order in which we cited Abrams v. Com-               
             missioner, 82 T.C. 403 (1984), and Rowlee v. Commissioner,               
             80 T.C. 1111 (1983), and we advised petitioner that the                  
             tax protester arguments set forth in the attachments to                  
             his trial memorandum had been considered and rejected by                 
             the Court in the past and would likely be rejected in this               
             case.  We warned petitioner that the Court could impose                  
             sanctions, pursuant to section 6673, if the Court found                  
             that a taxpayer's position in a proceeding was maintained                
             for delay or was frivolous or groundless.  Finally, we gave              
             petitioner an opportunity to submit a new trial memorandum               
             and to set forth arguments other than the tax protester                  
             arguments contained in his first trial memorandum.                       
             We advised petitioner that in the event he did not submit                
             a new trial memorandum, the Court would infer that he                    
             wished to proceed at trial on the basis of the arguments                 





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