Franklin Earl, Kish - Page 6

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          to file, petitioner must prove respondent's determinations wrong.           
          Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).                  
          Respondent must prove the determinations of fraud by clear and              
          convincing evidence.  Sec. 7454; Rule 142(b); Castillo v.                   
          Commissioner, 84 T.C. 405, 408 (1985).                                      
               Petitioner has not introduced any evidence that rebuts the             
          evidence submitted in support of respondent's determination of              
          the income tax deficiencies and additions thereto for which                 
          petitioner has the burden of proof.  Instead of attempting to               
          challenge the merits of respondent's determinations, petitioner             
          chooses to rely on shopworn assertions as to the validity of the            
          Federal income tax system and the authority of this Court to                
          conduct this proceeding.  All of petitioner's arguments are                 
          similar to rejected arguments of other taxpayers who have                   
          previously petitioned this Court in protest of their liability              
          for Federal income tax.  Petitioner's assertions in this case are           
          characteristic of the tax-protester rhetoric that has been                  
          universally rejected by this and other courts.  We will not                 
          painstakingly address petitioner's assertions as to the validity            
          of the Federal income tax system or the authority of this Court             
          "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 it to say that petitioner is subject to Federal income              





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