Greg Olson - Page 6

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                    There are specific rules (mainly in 26 CFR ��                     
                    1.861-8) describing when domestic income is                       
                    taxable (non-exempt), and describing when                         
                    foreign income is taxable.  Those rules only                      
                    show income to be taxable when derived from                       
                    certain specific sources and activities, all                      
                    of which are connected to international or                        
                    foreign commerce (including, among other                          
                    things, foreigners receiving income from the                      
                    U.S., and Americans receiving certain foreign                     
                    income).  Those rules do not show the                             
                    domestic income of most Americans to be                           
               As to the substance of petitioner’s motion, analogous                  
          arguments premised on section 861 and the regulations promulgated           
          thereunder have been repeatedly rejected.  E.g., Takaba v.                  
          Commissioner, 119 T.C. 285, 294-295 (2002); Williams v.                     
          Commissioner, 114 T.C. 136, 138-139 (2000); Dashiell v.                     
          Commissioner, T.C. Memo. 2004-210; Corcoran v. Commissioner, T.C.           
          Memo. 2002-18, affd. 54 Fed. Appx. 254 (9th Cir. 2002).  In                 
          Williams v. Commissioner, supra at 138, for instance, the                   
          taxpayer contended that his income, because not from any of the             
          sources listed in section 1.861-8(a), Income Tax Regs., was not             
          taxable.  This Court observed:                                              
                    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). * * * [Id. at 138-139.]                               
               Suffice it to say that we direct petitioner to this Court’s            
          recent detailed explanation and analysis in Dashiell v.                     

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