Tim W. Holliday - Page 9

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          1993, assessment.  Accordingly, the period of limitations for               
          collection of petitioner's 1992 liability is suspended and has              
          not expired.                                                                
               Further, with respect to the underlying tax liabilities,               
          petitioner contends that he asked the Appeals officer to tell him           
          which Internal Revenue Code section makes him liable for tax and            
          whether that section is within subtitle A.  Petitioner further              
          claims that he inquired as to what “legislative regulation” makes           
          him liable for interest.  In both instances, the Appeals officer            
          apparently refused to consider these inquiries.  These are                  
          frivolous issues that the Appeals officer might have responded to           
          but was certainly not required to consider.  Suffice it to say              
          that petitioner reported wage income for each of the years in               
          question and such income is taxable pursuant to sections 1(a)-              
          (c), 61(a)(1), and 62.  See also United States v. Romero, 640               
          F.2d 1014, 1016 (9th Cir. 1981).  As to petitioner's interest               
          liability, section 6601 provides for the imposition of interest             
          on unpaid tax liabilities, and section 6601(g) provides for the             
          assessment and collection of that interest.  See also sec.                  
          301.6601-1, Proced. & Admin. Regs.  In sum, the challenges to the           
          existence or amount of the underlying tax liabilities that                  
          petitioner advanced either at his hearing or in the instant                 
          proceeding are meritless.                                                   
               Finally, petitioner raised a frivolous argument to the                 
          effect that there had been no delegation of authority from the              




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