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Petitioner's so-called legal arguments or positions
were * * * concocted to avoid payment of tax * * * .
Petitioner's legal argument is an insidious form of
sophistry where he conglomerates material out of
chronological, historical, and textual sequence solely
to reach the conclusion that he does not have to pay
tax. His attempt to convince us that he is a
nonresident alien who did not earn income from domestic
sources at a time when he resided and earned his income
in the State of California falls short of even being
specious and must fail. It would be wasteful to
further elaborate or evaluate petitioner's contentions
in this opinion. * * *
Likewise, petitioner here may be a citizen of Kansas, but he is
also a citizen of the United States. The statutory material
relied upon by petitioner and included in the record is no more
convincing or authoritative than that cited in Hacker v.
Commissioner, supra.
As to petitioner's contention that he is not required to
file a return unless respondent can first demonstrate the legal
foundation for such requirement, the cases addressing and
rejecting that approach are numerous, and we need not waste time
reciting or analyzing them here. In this case, petitioner
admittedly failed to file returns. Respondent, based upon
information provided by third-party trucking companies,
determined that petitioner had income in each of 3 taxable years.
Petitioner, although petitioning this Court, has not shown
factual or legal error in respondent's determination of
petitioner's correct income tax liability for the years in issue.
In addition, respondent made a prima facie case for an increased
deficiency for 1994 and petitioner has not come forward with
evidence showing otherwise.
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