Michael Craig v. Commissioner - Page 20




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          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 intended             






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