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trial, counsel for respondent filed a motion asking us to impose
a penalty under section 6673. Petitioner received a copy of the
motion and supporting legal authority. At trial, petitioner
continued to maintain frivolous positions. He offered no
evidence relating to his income or deductions.
Discussion
A. Whether Petitioner Is Liable for Federal Income Tax
Petitioner bases his contention that he is not subject to
Federal income tax laws on frivolous arguments; e.g., that there
is no provision in the Internal Revenue Code making him liable
for any tax or requiring him to file a return. Petitioner's
assertions parrot those that courts have universally rejected.
We do not address petitioner's 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); see Wilcox v.
Commissioner, 848 F.2d 1007, 1008 (9th Cir. 1988) (rejecting
taxpayer’s claim that paying taxes is voluntary), affg. T.C.
Memo. 1987-225; Carter v. Commissioner, 784 F.2d 1006, 1009 (9th
Cir. 1986) (rejecting taxpayer's claim that the income tax is
voluntary); Rowlee v. Commissioner, 80 T.C. 1111, 1120 (1983)
(rejecting taxpayer's claim that he is not a "person liable" for
tax); Stone v. Commissioner, T.C. Memo. 1998-314 (stating that
section 6065 applies to returns and other documents filed with
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