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Some of the facts have been stipulated and are so found.
The stipulated facts and the accompanying exhibits are
incorporated herein by this reference. At the time the petition
in this case was filed, petitioners resided in Lubbock, Texas.
FINDINGS OF FACT
Petitioners did not file Federal income tax returns for the
years in issue.
Petitioner is retired from the U.S. Navy, and currently
works as a Federal protection officer at the Federal Building in
Lubbock, Texas.
Respondent based the determinations in this case on
information received from third-party payors. In addition,
petitioners have stipulated amounts of income that they received
for the years in issue in the form of wages, pension income,
nonemployee compensation, and interest.
OPINION
The Commissioner's determinations are presumptively correct,
and the taxpayer bears the burden of proving otherwise. See Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Petitioners do not challenge the facts on which respondent's
determinations are based, nor the calculation of tax. Instead,
petitioners argue that filing Federal income tax returns violates
their rights under the First, Fourth, and Fifth Amendments to the
U.S. Constitution. We now address their contentions in turn.
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