Joseph T. McQuatters - Page 13

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                  Petitioner did not file an income tax return for 1988.  The                           
            reasons given by petitioner for his failure to file are wholly                              
            frivolous and are similar to the 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.  See, e.g., Rowlee v.                                   
            Commissioner, 80 T.C. 1111, 1120 (1983); Frami v. Commissioner,                             
            T.C. Memo. 1997-509.  Petitioner attempted to support these                                 
            arguments by reference to statutes, regulations, and cases that                             
            are related to each other only in the sense that they all involve                           
            issues of taxation.  Petitioner's arguments are without merit and                           
            lack factual and legal foundation.  We are not obligated to                                 
            review exhaustively and rebut petitioner's misguided contentions.                           
            Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) ("We                             
            perceive no need to refute these arguments with somber reasoning                            
            and copious citation of precedent; to do so might suggest that                              
            these arguments have some colorable merit."); accord Kish v.                                
            Commissioner, T.C. Memo. 1998-16.  Petitioner's arguments are not                           
            adequate to show reasonable cause.  Accordingly, we sustain the                             
            additions to tax for delinquent filing as determined by                                     
            respondent.                                                                                 
                  Respondent also determined that petitioner was liable for                             
            additions to tax under section 6654(a) for failure to pay                                   
            estimated tax for 1988.  Where payments of tax, either through                              




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