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Congress to lay and collect taxes from whatever source derived”);
13th Amendment--Kasey v. Commissioner, 457 F.2d 369, 370 (9th
Cir. 1972)(ruling that there was no merit to the argument that
the “record keeping requirements and the requirement that
taxpayers shall prepare and file their tax returns, as
established by the Internal Revenue Code and the Internal Revenue
Service, violate their privilege against self-incrimination under
the Fifth Amendment and amount to involuntary servitude,
prohibited by the Thirteenth Amendment”) affg. 54 T.C. 1642
(1970); 16th Amendment--Abrams v. Commissioner, 82 T.C. 403, 406-
407 (1984)(“The Federal income tax laws are constitutional. * * *
The whole purpose of the 16th Amendment was to relieve all income
taxes when imposed * * * from a consideration of the source
whence the income was derived”).
IV. Additions to Tax
Respondent bears the “burden of production in any court
proceeding with respect to the liability of any individual for
any * * * addition to tax”. Sec. 7491(c). To meet this burden,
the Commissioner must come forward with sufficient evidence
indicating that it is appropriate to impose the relevant penalty
or addition to tax. Higbee v. Commissioner, 116 T.C. 438, 446
(2001). In instances where an exception to the penalty or
addition of tax is afforded upon a showing of reasonable cause,
the taxpayer bears the burden of showing such cause. Id. at 447.
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