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III. Conclusion
We believe that respondent has provided the required minimal
evidentiary foundation linking petitioner to an income-producing
activity. We shall reenter our order and decision in this case.3
An appropriate order and
decision will be entered.
3 We remain convinced that a penalty under sec. 6673(a)(1)
is deserved. In the main, petitioner’s response to respondent’s
determination of deficiencies has been to make frivolous or
groundless responses, undertaken, we believe, primarily for
delay. Petitioner has asserted absurd, discredited, and
misguided tax-protester arguments such as the following: (1) The
Internal Revenue Code does not make anyone “liable” for an income
tax, (2) the Internal Revenue Code contains no mandatory
provisions, and therefore, compliance is voluntary, (3) the Tax
Court has no authority to decide matters of law or constitutional
issues, and (4) an income tax on petitioner’s rents pursuant to
Pollock v. Farmers’ Loan & Trust Co., 158 U.S. 601 (1895), is an
unapportioned direct tax. Whether respondent had a basis for his
determinations or not (and we believe that he did), those
responses are without merit and inappropriate, and petitioner has
caused unnecessary work for both respondent and this Court.
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