-20- executed by the chief of the Automated Collection Branch in Ogden, Utah, was valid. As to petitioner’s remaining allegations, each allegation is a shop-worn, frivolous contention which “We perceive no need to refute * * * with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit.” Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984). Suffice it to say: 1. the Internal Revenue Code establishes the existence of his underlying tax liability and requires him to pay income tax, Tolotti v. Commissioner, T.C. Memo. 2002-86; 2. petitioner is a taxpayer subject to the Federal income tax, see secs. 1(c), 7701(a)(1), (14); 3. compensation for labor or services rendered constitutes income subject to the Federal income tax, sec. 61(a)(1); United States v. Romero, 640 F.2d 1014, 1016 (9th Cir. 1981); 4. petitioner is required to file an income tax return, sec. 6012(a)(1); and 5. petitioner’s failure to report tax on a return does not prevent the Commissioner from determining a deficiency in his Federal income tax, secs. 6211(a), 6212(a); see Monaco v. Commissioner, T.C. Memo. 1998-284. Petitioner has failed to raise a spousal defense, make a valid challenge to the appropriateness of respondent’s intendedPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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