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than a “hodgepodge of unsupported assertions, irrelevant
platitudes, and legalistic gibberish.” Crain v. Commissioner,
737 F.2d 1417, 1418 (5th Cir. 1984).
Petitioners’ arguments are completely baseless and have
repeatedly been rejected by this Court as well as the Court of
Appeals for the Fifth Circuit, the court to which an appeal in
this case would lie. See, e.g., id.; Parker v. Commissioner, 724
F.2d 469, 472 (5th Cir. 1984), affg. T.C. Memo. 1983-75; United
States v. McCarty, 665 F.2d 596, 597 (5th Cir. 1982); Lonsdale v.
Commissioner, supra.
We need not refute petitioners’ arguments with “somber
reasoning and copious citation of precedent”, as “to do so might
suggest that these arguments have some colorable merit.” Crain
v. Commissioner, supra at 1417. “The constitutionality of our
income tax system–-including the role played within that system
by the Internal Revenue Service and the Tax Court–-has long been
established.” Id. at 1417-1418.
3. Schedule C–-Adjustments to Income
The determinations of the Commissioner in a notice of
deficiency are presumed correct, and the burden is on the
taxpayer to show that the determinations are incorrect. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).5
5 Sec. 7491 does not apply in this case to place the
burden of proof on respondent because, among other reasons, the
(continued...)
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