Paula M. Olsen - Page 6

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          need to further respond to such arguments with somber reasoning             
          and copious citations of precedent, as to do so might suggest               
          that such arguments have some measure of colorable merit.  Crain            
          v. Commissioner, 737 F.2d 1417 (5th Cir. 1984).  In short,                  
          petitioner is a taxpayer subject to the income tax laws, and the            
          payments she received during the years at issue constituted gross           
          income subject to Federal income taxes.  Abrams v. Commissioner,            
          82 T.C. 403, 406-407 (1984).  Respondent is, therefore, sustained           
          on this issue.                                                              
               Section 6651(a)(1) provides for an addition to tax for a               
          taxpayer's failure to file timely returns, unless the taxpayer              
          can establish that such failure "is due to reasonable cause and             
          not due to willful neglect".  Petitioner's sole reason for filing           
          "statements" and "declarations" with respondent in lieu of income           
          tax returns was her stated disenchantment with the Internal                 
          Revenue Service because of collection actions taken against her             
          and her husband several years earlier for income tax deficiencies           
          arising out of their investment in a fraudulent tax shelter.                
          Petitioner felt that these actions against her and her husband              
          were unjustified when no punitive actions were taken against the            
          promoters of the shelter.  The Court does not view this position            
          as a reasonable cause for the failure to file income tax returns            
          and the failure to pay taxes.  Section 6654 provides for an                 
          addition to tax "in the case of any underpayment of estimated tax           

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