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Section 61(a) includes as gross income all income from
whatever source derived including, but not limited to,
compensation for services and interest. Sec. 61(a)(1), (4). At
trial, petitioner husband acknowledged the receipt of all items
of unreported income determined by respondent for the tax years
at issue. In doing so, it became apparent that petitioners'
erroneous interpretation of the Internal Revenue Code and claim
of foreign citizenship were the only arguments which they were
interested in presenting.
We will not address petitioners' tax-protester ramblings
which were presented at trial. As was stated by the Court of
Appeals for the Fifth Circuit, "We perceive no need to refute
these arguments with somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit." Crain v. Commissioner, 737 F.2d 1417, 1417
(5th Cir. 1984).
Since petitioners have presented no meritorious arguments
disputing respondent's proposed deficiencies, we sustain
respondent's determinations of deficiencies in petitioners' 1991,
1992, and 1993 Federal income taxes.
The second issue for decision is whether petitioners are
liable for the section 6651(a)(1) addition to tax for 1991.
Section 6651(a)(1) provides for an addition to tax of 5
percent of the tax required to be shown on the return for each
month or fraction thereof for which there is a failure to file a
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