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compensation is income. E.g., Beard v. Commissioner, 793 F.2d
139 (6th Cir. 1986), affg. per curiam 82 T.C. 766 (1984); Coleman
v. Commissioner, 791 F.2d 68, 70 (7th Cir. 1986); Carter v.
Commissioner, 784 F.2d 1006, 1009 (9th Cir. 1986); Olson v.
United States, 760 F.2d 1003, 1005 (9th Cir. 1985); United States
v. Burton, 737 F.2d 439, 441 (5th Cir. 1984); Gattuso v.
Pecorella, 733 F.2d 709, 710 (9th Cir. 1984); Funk v.
Commissioner, 687 F.2d 264, 265 (8th Cir. 1982), affg. T.C. Memo.
1981-506; Lonsdale v. Commissioner, 661 F.2d 71, 72 (5th Cir.
1981), affg. T.C. Memo. 1981-122; United States v. Romero, 640
F.2d 1014, 1016 (9th Cir. 1981).
Petitioner's arguments are basic protester rhetoric. As the
Court of Appeals for the Fifth Circuit has remarked: "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). We need not say any more.
Respondent's determination with respect to the deficiency
and additions to tax is sustained.
We now consider respondent's motion for an award of a
penalty against petitioner under section 6673(a).
As relevant herein, section 6673(a)(1) authorizes the Tax
Court to require a taxpayer to pay to the United States a penalty
not in excess of $25,000 whenever it appears that proceedings
have been instituted or maintained by the taxpayer primarily for
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