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not properly authorized to issue notices of deficiency is
frivolous and groundless. See id. at 165; Goza v. Commissioner,
supra. Likewise, petitioner’s argument that no statute
establishes an individual’s liability for income tax or requires
the payment of income tax is frivolous and groundless. 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); 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);
(3) petitioner is required to file an income tax return,
sec. 6012(a)(1); and
(4) a taxpayer’s failure to report tax on a return does not
prevent the Commissioner from determining a deficiency in that
taxpayer’s income tax, secs. 6211(a), 6212(a); see Monaco v.
Commissioner, T.C. Memo. 1998-284.
We likewise reject petitioner’s argument that the Appeals
officer failed to obtain verification from the Secretary that the
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