- 3 - determination. In his pretrial memorandum, petitioner stated that "his self assessment determined that he was not a 'taxpayer' as that word of art is used in the Internal Revenue Code". He further stated that he was not engaged in any taxable activity that would subject him to income tax. At trial, petitioner presented no evidence to refute respondent's deficiency determination. Discussion Instead of attempting to challenge the merits of respondent's determinations, petitioner raises the usual "tax protester" arguments which we and other courts have always rejected. See, e.g., Wilcox v. Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo. 1987-225. We do not believe it appropriate to address petitioner's assertions as to the validity of the Federal income tax system "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). Suffice to say, section 61(a)(1) includes in gross income compensation for services rendered, and it is undisputed that petitioner received $67,337 as wages from services rendered to the Northrop Grumman Corp. Respondent's deficiency determinations are presumed correct, and the burden is on petitioner to show that the determinations are wrong. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933).Page: Previous 1 2 3 4 5 Next
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