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Court, as well as other courts, and have been consistently
rejected. The Court sees no need to further respond to each of
petitioner's arguments with somber reasoning and copious
citations of precedent, to do so might suggest that petitioner's
arguments possess some measure of colorable merit. See Crain v.
Commissioner, 737 F.2d 1417 (5th Cir. 1984). In short,
petitioner is a taxpayer subject to the income tax laws and to
the jurisdiction of this Court. See Abrams v. Commissioner, 82
T.C. 403, 406-407 (1984).
On this record, the Court holds that petitioner is liable
for Federal income taxes on income of $2,040.63 for 1992, and
income of $21,909 for 1994, as determined by respondent in the
notices of deficiency. Respondent is, therefore, sustained on
this issue.
The second issue is whether petitioner is liable for the
addition to tax under section 6651(a)(1) for his failure to file
timely a Federal income tax return for 1994. Section 6651(a)(1)
imposes an addition to tax for a taxpayer's failure to file
timely returns, unless the taxpayer can establish that such
failure "is due to reasonable cause and not due to willful
neglect." Petitioner's 1994 income tax return was due to be
filed on or before April 15, 1995. Petitioner failed to file a
valid return for 1994. Sloan v. Commissioner, 102 T.C. 137
(1994), affd. 53 F.3d 799 (7th Cir. 1995); see supra note 5.
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