- 5 - respondent has the burden of proof as the proponent of rules; and (8) the notice of deficiency violates sections 3504(h), 3507(a), and 3512 of the Paperwork Reduction Act of 1980, 44 U.S.C. secs. 3501-3520 (1988).1 Petitioner's contentions are a rehash of frivolous tax protester arguments. See Wilcox v. Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo. 1987-225; United States v. Romero, 640 F.2d 1014 (9th Cir. 1981). His arguments 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 address petitioner's contentions here. 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. Deficiency Petitioner stipulated that he received the amounts of income as determined by respondent.2 1 See Aldrich v. Commissioner, T.C. Memo. 1993-290 and cases cited therein, for a discussion of the effect of the Paperwork Reduction Act of 1980, 44 U.S.C. secs. 3501-3520 (1988), on the deficiency process. 2 Respondent determined and concedes that petitioner may deduct $15 for forfeited interest. Petitioner did not know that he was entitled to deduct that amount.Page: Previous 1 2 3 4 5 6 7 8 Next
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