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Cir. 1990); United States v. Richards, 723 F.2d 646, 648 (8th
Cir. 1983); Grimes v. Commissioner, 82 T.C. 235, 237 (1984).
Petitioner does not contest the amounts of compensation and
gain upon which respondent based his deficiency determinations.
Indeed, with minor exceptions, petitioner stipulated that he
received the amounts determined by respondent for the tax years
at issue.2 However, petitioner argues that the income tax is an
excise tax and that petitioner did not engage in any taxable
excise activities during 1996, 1997, and 1998.
The contentions made by petitioner in his petition and on
brief are appropriately termed “tax protester rhetoric and
legalistic gibberish”, and we shall not dignify such arguments
with any further discussion.3 Crain v. Commissioner, 737 F.2d
1417, 1418 (5th Cir. 1984); Lindsay v. Commissioner, T.C. Memo.
2001-285; Black v. Commissioner, T.C. Memo. 1995-560. We hold
that petitioner’s wages, nonemployee compensation, and gain from
2The only amounts of income in respondent’s determinations
that were not stipulated were $275 of wages in 1996 and $263 of
wages in 1997. Respondent requested that petitioner admit or
deny that he received those amounts as taxable income in taxable
years 1996 and 1997. Petitioner objected to those requests as
legal conclusions, but he does not dispute that he received those
amounts as wages during the years at issue.
3In Hart v. Commissioner, T.C. Memo. 2001-306, the taxpayer
raised similar arguments; i.e., that “The income tax is an
‘excise tax’, and he did not engage in any ‘excise taxable
activity’”. We rejected the taxpayer’s contention that he owed
no income taxes on the wages he received.
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