William C. Reichenbach - Page 5

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               As to all issues, respondent's 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).                                                            
          I.  Respondent's Deficiency Determination                                   
               The first issue for decision is whether petitioner is liable           
          for the deficiencies determined by respondent.  Respondent's                
          deficiency determinations are based on petitioner's receipt of              
          wages, gain from the sale of property, taxable distributions from           
          qualified retirement plans, and the section 72(t) 10-percent                
          additional tax for early distributions from qualified retirement            
          plans.  Instead of attempting to challenge the merits of                    
          respondent's determinations, petitioner raises numerous "tax                
          protester" arguments.3  We shall not 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).                 
               Section 61(a) defines an individual's gross income as "all             
          income from whatever source derived".  Respondent determined that           
          compensation for services, gains derived from dealings in                   

               3  Among other things, petitioner makes the following                  
          arguments:  That wages are not taxable income, and that the Forms           
          W-2 show only "employment taxes withheld" and not any kind of tax           
          owed by him.                                                                

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