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Goza v. Commissioner, supra. As the Court of Appeals for the
Fifth Circuit has remarked: “We perceive no need to refute these
arguments 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 that petitioners are
taxpayers subject to the Federal income tax, see secs. 1(a)(1),
7701(a)(1), (14), and that 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).
We likewise reject petitioners’ 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 the Appeals officer obtained and reviewed a Form 4340 with
regard to petitioners’ taxable year 1998.
Federal tax assessments are formally recorded on a record of
assessment. Sec. 6203. “The summary record, through supporting
records, shall provide identification of the taxpayer, the
character of the liability assessed, the taxable period, if
applicable, and the amount of the assessment.” Sec. 301.6203-1,
Proced. & Admin. Regs.
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