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disputed respondent's determination that he received unemployment
compensation in 1994 from the Commonwealth of Kentucky.
Respondent proffered evidence that convinces the Court that
petitioner did not file income tax returns or pay any estimated
tax (in addition to the tax withheld) with respect to any of the
taxable years at issue.
Petitioner's brief contains outworn arguments about the
unconstitutionality of the Federal income tax in its application
to earned income that are refuted by numerous court opinions,
including the opinions cited supra note 1, which were provided to
petitioner before the trial resulting from his refusal to concede
respondent's determinations. Those opinions establish that the
compensation paid to petitioner during the taxable years in
question is included in his gross income and is subject to
Federal income tax. Petitioner's arguments are without merit,
and he is liable for income tax and additions to tax as
determined by respondent. No useful purpose would be served by
any further explanation.
Turning to respondent's motion for a penalty under section
6673, we observe that, in each of the cases cited supra note 1, a
penalty had been imposed under section 6673, which now provides
for imposition of a penalty of up to $25,000 against a party who
advances frivolous or groundless positions or institutes or
maintains a proceeding primarily for delay. Petitioner has
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