Karen and Gary Fujita - Page 4




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                                       OPINION                                         
               Petitioners do not challenge the facts on which respondent's            
          determinations are based, nor the calculation of tax.                        
          Petitioners have stipulated that they received, among other                  
          things, wages and interest during the taxable years at issue.                
          Petitioners' argument is merely that they have not been shown any            
          law that provides they are subject to tax.  This is not accurate.            
          Respondent's trial memorandum provided petitioners with legal                
          authority regarding their duties as taxpayers.  At trial, the                
          Court also directed petitioners' attention to section 61(a)                  
          regarding gross income.  Nevertheless, petitioners continue to               
          seek to avoid the incidence of Federal income tax by advancing               
          hackneyed rhetoric that has been universally rejected by this and            
          other courts.  See, e.g., Wilcox v. Commissioner, 848 F.2d 1007              
          (9th Cir. 1988), affg. T.C. Memo. 1987-225.  We shall not                    
          painstakingly address petitioners' assertions "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 to            
          say, petitioners are subject to Federal income tax during the                
          relevant years, and we sustain respondent's deficiency                       
          determinations.                                                              
               In addition, respondent determined additions to tax under               
          sections 6651(a) and 6654(a), and an accuracy-related penalty                





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