Alex B. Rhodes, Jr. - Page 4

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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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