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an exchange of intellectual and physical property for an agreed
upon perceived value in the only medium of exchange of the day
i.e. FRN’s [Federal Reserve Notes]”. Petitioner also contended
that he is “a ‘native born American national’, not to be mistaken
as a ‘U.S. CITIZEN’” or taxpayer.
Petitioner is no stranger to the Court. Petitioner has
litigated two cases very similar to this instant case in which
petitioner did not file Federal income tax returns, respondent
determined deficiencies and additions to tax, and petitioner
presented arguments similar to those asserted here. In a 2001
trial (2001 trial) that resulted in a bench opinion, the Court
explained to petitioner that taxable income includes money and
other goods received in exchange for services and urged
petitioner to file returns. In a 2005 trial (2005 trial), the
Court again rejected petitioner’s arguments and awarded the
United States a penalty pursuant to section 6673 in the amount of
$5,000. Leggett v. Commissioner, T.C. Memo. 2005-185.
OPINION
I. Deficiency
In general, respondent’s determination of a deficiency in
the notice of deficiency is presumed correct, and petitioner
bears the burden of showing that such determination was in error.
See Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
Pursuant to section 7491(a), the burden of proof on factual
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