Hubert W.N. Chang - Page 8




                                        - 8 -                                         
               Throughout this case, petitioner also presented                        
          tax-protester arguments, including:  (1) Respondent has no                  
          jurisdiction over him; (2) the Internal Revenue Service has not             
          complied with the Paperwork Reduction Act; and (3) respondent               
          lacks authority to assert income tax deficiencies.  Petitioner’s            
          assertions have been rejected by this Court and other courts, and           
          “We perceive no need to refute these arguments 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); see, e.g.,            
          Wheeler v. Commissioner, 127 T.C. 200, 204 n.9 (2006) (rejecting            
          as without merit the argument that the requirement to file a tax            
          return is in violation of the Paperwork Reduction Act); Nunn v.             
          Commissioner, T.C. Memo. 2002-250 (rejecting as without merit the           
          argument that the Federal income tax is unconstitutional).  This            
          Court rejects petitioner’s tax-protester arguments as frivolous             
          and without merit.  Because petitioner did not raise a valid                
          claim, such as a spousal defense or an alternative means of                 
          collection, such claims are deemed to be conceded.  See Rule                
          331(b)(4).                                                                  
               Petitioner’s arguments do not present justiciable issues;              
          they ignore established law and give no basis for his claim that            
          respondent abused his discretion in sustaining the Federal tax              
          lien.  This Court concludes that respondent’s determination to              







Page:  Previous  1  2  3  4  5  6  7  8  9  Next 

Last modified: November 10, 2007