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penalty, and interest that respondent assessed against petitioners.
With regard to the underlying tax deficiency determined by
respondent against petitioners, even if such tax deficiency were
properly before us, most courts would not dignify petitioners’
particular tax protester argument by addressing it at length in a
written court opinion. For example, in Williams v. Commissioner,
114 T.C. 136, 138-139 (2000), wherein the taxpayers made the same
argument as the petitioners herein make about sections 61 and
861, we stated as follows:
Petitioner’s arguments are reminiscent of tax-protester
rhetoric that has been universally rejected by this and
other courts. 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.” Crain v.
Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984). * * *
In our discretion, however, herein we provide to petitioners
an explanation as to why their 1997 wage and other income
constitute taxable income. We do so only with the hope that
petitioners will consider themselves personally addressed, that
they will consider themselves to have had their day in court, and
that petitioners will find such explanation persuasive and
convincing and will come back into compliance with the Federal
income tax system.
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