- 4 -
Petitioners do not challenge the facts on which respondent's
determinations are based or respondent's calculation of tax.
Petitioners stipulated that during 1993, 1994, and 1995 Mr. Morin
received compensation from Les Morin Subaru, a retirement
distribution, and prizes from Subaru of America, Inc.
Petitioners have not demonstrated that any exception contained in
the tax laws excludes the prizes or the retirement distribution
from income. Instead, petitioners advanced shopworn arguments
characteristic of tax-protester rhetoric that has been
universally rejected by this and other courts. See Wilcox v.
Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo.
1987-225; Carter v. Commissioner, 784 F.2d 1006, 1009 (9th Cir.
1986). Petitioners allege: (1) The wages they received are not
income; (2) the Internal Revenue Service did not send a notice of
deficiency and did not file a return as mandated by section
6020(b); (3) petitioners were not employees; (4) petitioners did
not receive any wages as defined by section 3121; and (5) taxing
their wages violates the Sixteenth Amendment. 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).
Accordingly, we sustain respondent's determination that these
amounts are income.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011