Anthony M. Davich - Page 16




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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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