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reflected on Forms 1099-MISC, Miscellaneous Income, must be
apportioned, and since no tax is apportionable to them, they had
no tax liability. Petitioners advanced these and other arguments
in filings and at the summary judgment hearing. These arguments
are characteristic of tax-protester rhetoric that has been
universally rejected by this and other courts. 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 petitioners’
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).
Accordingly, we conclude that petitioners are liable for the
deficiency determined by respondent.
III. Penalties
A. Section 6662(a)
Pursuant to section 6662(a), a taxpayer may be liable for a
penalty of 20 percent on the portion of an underpayment of tax
due to negligence or disregard of rules or regulations or a
substantial understatement of income tax. Sec. 6662(b). An
“understatement” is the difference between the amount of tax
required to be shown on the return and the amount of tax actually
shown on the return. Sec. 6662(d)(2)(A). A “substantial
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