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unemployment compensation, and interest do not constitute gross
income.
Petitioners argue: (1) There is no law making petitioners
liable for a personal income tax; (2) petitioners have no gross
income pursuant to section 861 et seq. concerning gross income
from sources within the United States and without the United
States; and (3) the notice of deficiency with respect to
petitioners’ 1998 return is invalid because petitioners allegedly
were denied an administrative hearing and because respondent
failed to carry the burden of proof at the administrative level.
At the outset we note that petitioners’ arguments are
without factual or legal foundation. Their contentions are
reminiscent of standard tax protester rhetoric. They have
presented as exhibits copies of materials apparently prepared and
distributed by an organization opposed to compliance with the
income tax laws. While petitioners’ arguments certainly do not
require refutation “with somber reasoning and copious citation of
precedent”, Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984),
we shall, nevertheless, briefly discuss some of the issues
raised.
Section 1 imposes an income tax on the income of every
individual who is a citizen or resident of the United States.
Sec. 1.1-1(a)(1), Income Tax Regs. Section 61(a) provides that
except as otherwise provided in subtitle A (income taxes) gross
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