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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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