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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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