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Even if petitioners were permitted to challenge the validity
of the notice of deficiency, petitioners’ arguments are frivolous
and groundless. See Nestor v. Commissioner, 118 T.C. 162, 165
(2002); 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,
see 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 Forms 4340 with
regard to petitioners’ taxable years 1992, 1993, and 1994.
Federal tax assessments are formally recorded on a record of
4(...continued)
petitioners do not point to any discrepancy in the record or set
forth specific facts that would suggest that there is a genuine
issue for trial whether these items were properly assessed. See
Rule 121(d).
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