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(9th Cir. 1983), affg. 76 T.C. 1027 (1981); Edwards v.
Commissioner, 680 F.2d 1268 (9th Cir. 1982); United States v.
Carlson, 617 F.2d 518, 523 (9th Cir. 1980). In a civil tax case,
the taxpayer must accept the consequences of asserting the Fifth
Amendment and cannot avoid the burden of proof by claiming the
privilege and attempting to convert “the shield * * * which it
was intended to be into a sword”. United States v. Rylander, 460
U.S. 752, 758 (1983); see Steinbrecher v. Commissioner, supra;
Traficant v. Commissioner, 89 T.C. 501 (1987), affd. 884 F.2d 258
(6th Cir. 1989).
Petitioner also contends that respondent erroneously relied
on third-party information to determine that he had unreported
income for the years in issue. He has not, however, raised any
bona fide dispute as to the amounts reported on the third-party
documents. The only dispute that petitioner raised with respect
to the amounts of compensation is his frivolous arguments that
his wages are not taxable. Those arguments, as petitioner was
advised in the District Court order, citing United States v.
Studley, 783 F.2d 934, 937 (9th Cir. 1986), have been
consistently and thoroughly rejected and may be the basis for
sanctions. See also Rowlee v. Commissioner, 80 T.C. 1111, 1119-
1122 (1983). In these circumstances, respondent was entitled to
rely on the third-party information. See Parker v. Commissioner,
117 F.3d 785 (5th Cir. 1997); see also sec. 6201(d). In any
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