- 17 -
Commissioner, supra at 165; Goza v. Commissioner, supra.
Further, 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 petitioner is a taxpayer 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); see also sec. 86
regarding the taxability of unemployment compensation.
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 the Appeals officer obtained and reviewed transcripts of
petitioner’s accounts for 1997 and 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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