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Government-sanctioned entities may constitutionally be subjected
to individual income tax. Under petitioner’s theory, the
prohibited disparity results from taxing those whose income
derives in some way from a legislatively authorized entity in the
same manner as those who do not receive a similar benefit.
This Court has repeatedly held taxpayers to be liable for
taxes on income accruing from self-employment, sole
proprietorship, or nonemployee activities, despite the tax
protester rhetoric advanced in contending for the opposite
result. See, e.g., Kish v. Commissioner, supra; Minguske v.
Commissioner, supra; Frami v. Commissioner, supra; Fisher v.
Commissioner, supra. Arguments by such individuals that they do
not hold the status of “taxpayer” or “person” within the meaning
of the Internal Revenue Code have been summarily dismissed as
well. See, e.g., Kish v. Commissioner, supra; Fisher v.
Commissioner, supra.
Petitioner’s position is untenable. Since petitioner has
offered no further evidence establishing that respondent’s
determinations are erroneous, we hold that petitioner is liable
for the deficiencies as determined by respondent.
In addition, section 6651(a) provides, in relevant part, as
follows:
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Last modified: May 25, 2011