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$5,920, unemployment compensation of $3,705, interest of $20,
dividends of $36, and wages of $20,131. Petitioner did not file
income tax returns for 1990, 1994, or 1996.
I. Unreported Income
Respondent determined that all of petitioner’s receipts
during the years in issue were income to petitioner. Petitioner
does not dispute that he received the income; rather, he contends
there is insufficient authority to hold him liable for an income
tax.
The crux of petitioner’s argument is found in his trial
memorandum and supplement to trial memorandum.4 These trial
memoranda are merely lists of disjointed brief quotations and
erroneous statements of law. Giving petitioner the benefit of
the doubt, we construe petitioner’s argument to be that the
income tax is unconstitutional and, alternatively, that the
definition of income excludes his receipts. We reject
4The Court directed the parties to file simultaneous briefs,
together with simultaneous reply briefs. Petitioner did not file
a brief. We could declare petitioner in default and dismiss his
case. See Rule 123; Stringer v. Commissioner, 84 T.C. 693
(1985), affd. without published opinion 789 F.2d 917 (4th Cir.
1986); Pace v. Commissioner, T.C. Memo. 2000-300. We also could
conclude that petitioner abandoned his claims after trial and
decide this case against petitioner because he failed to meet his
burden of proof. See Calcutt v. Commissioner, 84 T.C. 716, 721-
722 (1985); Hartman v. Commissioner, T.C. Memo. 1999-176. We
choose, instead, to decide the case on the merits in the hope
that this opinion will guide petitioner’s future decisions
regarding his tax obligations. See Calcutt v. Commissioner,
supra at 721-722; Pace v. Commissioner, supra; Bissell v.
Commissioner, T.C. Memo. 1991-163.
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