- 3 -
ment account, and/or capital gain. According to the notices,
respondent relied on, inter alia, certain information returns,
petitioner's 1992 return, and/or the Consumer Price Index roll-
over method (CPI rollover method) to reconstruct petitioner's
income for each of the years at issue. Respondent also deter-
mined in the notice, inter alia, that petitioner is not entitled
to certain deductions that petitioner claimed in Schedule C,
Profit or Loss From Business, and Schedule E, Supplemental Income
and Loss (Schedule E), of his 1992 return.
After petitioner filed the petition in this case, he did not
cooperate with respondent in preparing this case for trial or in
settling it, although he did submit a trial memorandum which the
Court had filed on October 27, 1997. In his trial memorandum,
petitioner advanced protester type contentions that have been
rejected by the courts as frivolous and/or groundless.2
2 By way of illustration, petitioner states, inter alia, in his
trial memorandum the following:
I have relied on the professional opinion of attorneys,
who have not been rebutted by the IRS, that (a) there is no
statute that compels anyone and everyone to filing and
assessing themselves a 1040 Tax [sic] and (b) Title 26, the
Income Tax Code cannot be enforced outside of the federal
government's jurisdiction, absent voluntary self assessment
by those outside such jurisdiction. Enacted Federal law is
limited by the Constitution to "10 Square Miles", Article I
Section 8. The fact that federal law cannot automatically
and presumptively extend into the States has been recon-
firmed by the Supreme Court * * *. The only way that
federal legislation becomes effective outside the territo-
ries and possessions of the U.S. is by voluntary participa-
(continued...)
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