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At trial, petitioner conceded that the Forms W-2 from EDS
for 2000 and 2001 and the exhibits listing the dividends and
interest for 2000 and 2001 are accurate and that he was paid the
wages listed in the Forms W-2 by EDS. Petitioner, however,
disputed that the aforementioned amounts are income.
Accordingly, since petitioner does not dispute the facts, failed
to introduce credible evidence, and has not asserted a reasonable
dispute regarding the items listed on the information returns,
sections 6201(d) and 7491(a) are inapplicable. Parker v.
Commissioner, 117 F.3d 785, 786 (5th Cir. 1997); Tanner v.
Commissioner, 117 T.C. 237, 241 (2001), affd. 65 Fed. Appx. 508
(5th Cir. 2003).
At trial and on brief, petitioner advanced shopworn
arguments regarding why the wages, interest, and dividends are
not income. His arguments are characteristic of tax-protester
rhetoric that has been universally rejected by this and other
courts. See Wilcox v. Commissioner, 848 F.2d 1007 (9th Cir.
1988), affg. T.C. Memo 1987-225; Carter v. Commissioner, 784 F.2d
1006, 1009 (9th Cir. 1986). 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).
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