Walter E. Peterson - Page 5

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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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