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additions to tax at issue. They are instead recastings of
contentions which we have termed "nothing more than tax protester
rhetoric and legalistic gibberish, which have absolutely no
merit”. Howard v. Commissioner, T.C. Memo. 1998-57.7 We decline
to address them further. In McCoy v. Commissioner, 76 T.C. 1027,
1029-1030 (1981), affd. 696 F.2d 1234 (9th Cir. 1983), we stated
that
The time has arrived when the Court should deal
summarily and decisively with such cases without
engaging in scholarly discussion of the issues or
attempting to soothe the feelings of the petitioners by
referring to the supposed "sincerity" of their wildly
espoused positions.
C. Self-Employment Tax
Section 1401 imposes a tax on an individual’s self-
employment income, which is defined as the net earnings from
self-employment derived by an individual during the taxable
years. See sec. 1402(b). Net earning from self-employment means
gross income, less certain deductions, derived by an individual
from any trade or business carried on by the individual. See
7 Before trial and on brief, petitioner asserted that he did
not understand the word "income". At calendar call we referred
petitioner to members of the Taxation Section of the California
Bar Association who were present in the courtroom, explaining
that they had offered to assist with such questions on a pro bono
basis. Petitioner declined to accept our referral. Petitioner's
obvious intelligence and experience in conducting business makes
us doubt his sincerity in arguing that he failed to understand
the concept of "income". Instead, his consistently frivolous
contentions indicate that his asserted misunderstanding of the
word "income" was willful, based upon discredited tax-protester
arguments that the income he undoubtedly received was somehow
something else. Cf. United States v. Buras, 633 F.2d 1356, 1361
(9th Cir. 1980); Rowlee v. Commissioner, 80 T.C. at 1120-1122.
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