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earnings for 1992 and 1993. Petitioner argues, inter alia, that
(1) the income tax is an invalid excise tax; (2) he is not
subject to the income tax since he is a resident of the United
States and a citizen of the State of Washington whose citizenship
does not depend upon immigration and naturalization or upon the
13th, 14th, and 15th Amendments; he is not subject to tax on his
earnings from his labor; and the Commissioner is only authorized
to collect taxes paid by stamp, whereas petitioner is not engaged
in an activity that requires him to buy stamps.
Petitioner's positions are wholly frivolous. The 16th
Amendment authorizes the imposition of a nonapportioned direct
income tax on U.S. citizens residing in the United States. See
In re Becraft, 885 F.2d 547 (9th Cir. 1989); Wilcox v.
Commissioner, 848 F.2d 1007, 1008 (9th Cir. 1988), affg. T.C.
Memo. 1987-225; Rowlee v. Commissioner, 80 T.C. 1111, 1121-1122
(1983). Furthermore, U.S. citizens' wages are income, and this
income may be taxed without apportionment. See Wilcox v.
Commissioner, supra; Rowlee v. Commissioner, supra. Petitioner's
other arguments are equally misguided, and such arguments have
been repeatedly rejected by this and other Federal courts. See,
e.g., Wilcox v. Commissioner, supra (paying taxes is not
voluntary); Talmage v. Commissioner, T.C. Memo. 1996-114 n.3
(section 6201 grants assessment authority with respect to all
taxes as to which returns or lists are made under the code,
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