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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.
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