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multiple ways respondent’s forms allegedly violated the Paperwork
Reduction Act (PRA). Petitioner repeatedly failed to cooperate
with respondent because respondent allegedly failed to prove a
delegation of authority, and petitioner repeated the delegation
of authority argument in its reply brief. Petitioner also argued
that even if the workers in question were its employees, they
received nontaxable income and not wages. Finally, petitioner
questioned the validity of the notice of determination because it
“did not contain any statutes telling the Petitioner what
statutes created the duty that it must pay someone else’s taxes.”
The courts have consistently held all of these arguments to
be frivolous and without merit. See James v. United States, 970
F.2d 750, 753 n.6 (10th Cir. 1992) (rejecting taxpayer’s
arguments regarding invalid OMB numbers and violations of PRA);
Wilcox v. Commissioner, 848 F.2d 1007, 1008 (9th Cir. 1988)
(rejecting taxpayer’s arguments that wages are not income), affg.
T.C. Memo. 1987-225; Wheeler v. Commissioner, T.C. Memo. 2006-109
(rejecting taxpayer’s arguments regarding validity of notice of
deficiency); Nunn v. Commissioner, T.C. Memo. 2002-250 (rejecting
challenge to Internal Revenue Service jurisdiction over taxpayers
and documents). We warned petitioner’s agent on at least two
occasions that if petitioner continued to raise frivolous
arguments, we would impose a penalty under section 6673. After
each warning, petitioner continued to assert its frivolous
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