- 4 - Petitioner stipulated that he received the income listed on the notice of deficiency.2 Petitioner contends, inter alia, that the earnings he received are not income, and therefore he is not liable for taxes. Petitioner also argues that the statutory notice of deficiency he received is invalid because it was not signed by the Secretary of the Treasury or an agent designated by the Secretary. Petitioner advanced these and other arguments in filings and at the hearing. These arguments are characteristic of tax-protester rhetoric that has been universally rejected by this and other courts. Casper v. Commissioner, 805 F.2d 902 (10th Cir. 1986), affg. T.C. Memo. 1985-154; Charczuk v. Commissioner, 771 F.2d 471 (10th Cir. 1985), affg. T.C. Memo. 1983-433; Michael v. Commissioner, T.C. Memo. 2003-26; Knelman v. Commissioner, T.C. Memo. 2000-268, affd. without published opinion 33 Fed. Appx. 346 (9th Cir. 2002). 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). Accordingly, we conclude that petitioner is liable for the deficiency determined by respondent. 2 Petitioner received payments totaling $35,873 from various sources including wages, unemployment compensation, income from self-employment, and IRA distributions.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011