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petitioner’s wages for 1999, petitioner paid no Federal income
tax for 1998 and 1999.
OPINION
Petitioner claims that his income from wages and investments
does not constitute taxable income. Petitioner misreads case
law, statutory language, and related Treasury regulations.
Petitioner’s arguments are frivolous. See Takaba v.
Commissioner, 119 T.C. 285 (2002); Williams v. Commissioner,
114 T.C. 136 (2000).
As stated in Williams v. Commissioner, supra, “we shall not
painstakingly address petitioner’s assertions ‘with somber
reasoning and copious citation of precedent; to do so might
suggest that these arguments have some colorable merit.’” Id.
at 139 (quoting Crain v. Commissioner, 737 F.2d 1417, 1417 (5th
Cir. 1984), affg. per curiam an order of this Court).
We conclude that the wage and investment income that
petitioner received during 1998 and 1999 is includable in
petitioner’s taxable income. See sec. 61(a).
Section 162(a) generally provides taxpayers with deductions
for ordinary and necessary business expenses. Where taxpayers
would have been reimbursed by their employers for business
expenses incurred, but where they failed to receive reimbursement
because they failed to request reimbursement, the expenses will
not be considered “necessary” and will not be deductible. Orvis
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