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published opinion 991 F.2d 795 (6th Cir. 1993)(citing Edgar v.
Finley, 312 F.2d 533 (8th Cir. 1963)).
Despite repeated requests for documents by respondent before
and at the trial of the instant case, petitioner failed to
substantiate his contention that he had basis in the company’s
stock through the contribution of cash he obtained from a
refinancing of the note.5 Indeed, petitioner refused to address
that issue, preferring to rely on frivolous arguments.
We deny petitioner’s motion to reopen the record because,
among other reasons, it is prejudicial to respondent, but note
that, even if we were to admit the documents petitioner wishes to
submit, the documents fail to support petitioner’s contention
that he is personally liable on a refinancing of the note, that
the company was relieved of its debt pursuant to the note, and
that he actually contributed the proceeds of the refinancing of
the note to the capital of the company.
We do not address with somber reasoning and copious
citations of precedent petitioner’s arguments that he is not
required to file tax returns or pay income tax, as to do so might
suggest that petitioner’s arguments possess some degree of
colorable merit. See Crain v. Commissioner, 737 F.2d 1417, 1417
5Petitioner claims he has basis in his stock of the company
sufficient to offset capital gains distributions he received from
the company.
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