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independent investigation" by the IRS in all unreported income
cases. Parker v. Commissioner, 117 F.3d 785, 787 (5th Cir.
1997), affg. per curiam an Order of this Court. Where a taxpayer
does not dispute that he received the payment in question as
reported on a third-party information return, the Commissioner
has no duty to investigate. See id. And where the taxpayer
fails to dispute a connection with the tax-generating income, the
"naked assessment" doctrine does not apply. See Parrish v.
Commissioner, 168 F.3d 1098, 1100-1101 (8th Cir. 1999), affg.
T.C. Memo. 1997-474; Day v. Commissioner, 975 F.2d 534, 537 (8th
Cir. 1992), affg. in part and revg. in part on another issue T.C.
Memo. 1991-140; Zuhone v. Commissioner, 883 F.2d. 1317, 1326 (7th
Cir. 1989), affg. T.C. Memo. 1988-142; Andrews v. Commissioner,
T.C. Memo. 1998-316.
Petitioner denies in his trial memorandum that he was an
"'employee,' engaged in 'employment' or 'self-employment'" in
either 1994, 1995, or 1996 or that he received "'wages' or 'non-
employee compensation'" in those years. Considering petitioner's
legal arguments and the evidence in the record in this case, we
interpret his use of quotation marks around words such as
"employee" and "wages" to mean that petitioner uses those terms
in a personal way that has a special meaning to him, not as they
are ordinarily understood.
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