Roland Allen Pelletier - Page 7

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                  When this case was called for trial and for a hearing               
             on respondent's motion for judgment on the pleadings,                    
             petitioner called no witnesses and offered no documents                  
             or other evidence for the record.  Petitioner merely                     
             reiterated the tax protester arguments that are set forth                
             in the attachments to his trial memorandum.  Specifically,               
             petitioner argued that the 16th Amendment to the                         
             Constitution is unconstitutional and that wages are not                  
                  As we advised petitioner in the Order described above,              
             petitioner's arguments have previously been considered and               
             rejected by this and other courts.  See, e.g., United                    
             States v. Connor, 898 F.2d 942 (3d Cir. 1990); Coleman v.                
             Commissioner, 791 F.2d 68, 70 (7th Cir. 1986); Connor v.                 
             Commissioner, 770 F.2d 17, 20 (2d Cir. 1985); Perkins v.                 
             Commissioner, 746 F.2d 1187, 1188 (6th Cir. 1984), affg.                 
             per curiam T.C. Memo. 1983-474; Funk v. Commissioner, 687                
             F.2d 264, 265 (8th Cir. 1982), affg. per curiam T.C. Memo.               
             1981-506; Abrams v. Commissioner, supra; Rowlee v.                       
             Commissioner, supra.                                                     
                  In view of the fact that petitioner called no                       
             witnesses and introduced no other evidence into the                      
             record, we find that petitioner has not met his burden                   
             of disproving the determinations made by respondent in                   

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