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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).
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