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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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