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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); see Tolotti v. Commissioner,
T.C. Memo. 2002-86. Suffice it to say:
(1) Petitioner is a taxpayer subject to the Federal income
tax, see secs. 1(c), 7701(a)(1), (14);
(2) 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); see also
sec. 61(a)(4);
(3) petitioner is required to file an income tax return,
sec. 6012(a)(1); and
(4) the Commissioner and his agents are authorized to
enforce the provisions of the Internal Revenue Code, see I.R.C.
chs. 78, 80.
We likewise reject petitioner’s argument that the Appeals
officer failed to obtain verification from the Secretary that the
requirements of all applicable laws and administrative procedures
were met as required by section 6330(c)(1). The record shows
that prior to the administrative hearing on July 30, 2001, the
Appeals officer obtained and reviewed computerized transcripts of
account for petitioner’s taxable years 1997 and 1998.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. “The summary record, through supporting
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