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provide this evidence both prior to and at trial, and he
stubbornly refused to do so. Moreover, petitioner refused to
abide by the Court’s standing pretrial order that requires all
documents that a party expects to utilize at trial be provided to
the other party at least 14 days in advance of the trial
calendar. Accordingly, petitioner’s motion to reopen the record
is denied.
Gross income includes interest and pension income. Sec.
61(a)(4), (11). Petitioner does not deny that he received the
interest and pension income but argues that the pension income is
“labor property” and that the interest income is so insignificant
that it falls below the threshold requiring him to file. We
understand petitioner’s argument to mean that he receives his
pension income from his former employer for whom he once
performed services (or labor), and that any amount he receives in
exchange for his labor is a nontaxable exchange of equal value.
That argument has been rejected by every court that has addressed
the issue and is the type of frivolous tax protester argument
that wastes the Court’s time and resources. We do not address
petitioner’s “labor property” argument with somber reasoning and
copious citations of precedent, as to do so might suggest that
petitioner’s argument possesses some degree of colorable merit.
See Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).
Petitioner’s total pension and interest income for each taxable
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