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property he depreciated in connection with the same activity does
not satisfy the trade or business requirement of section 167.
Therefore, this Court finds petitioner is not entitled to the
depreciation deduction of $3,479.
The expenses petitioner purportedly incurred, if
substantiated, were at best start-up expenditures. Startup
expenses are not deductible unless an election is made to
amortize them under section 195(b) over a period starting when an
active trade or business begins. See sec. 195(a). Petitioner
did not make an election under section 195(b).
II. Tax-Protester Arguments
Petitioner also argued that respondent had not complied with
the Paperwork Reduction Act and lacked the authority to assert
income tax deficiencies. Petitioner’s arguments 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) (an allegation that
the requirement to file a tax return is in violation of the
Paperwork Reduction Act is contrary to well-established law);
Nunn v. Commissioner, T.C. Memo. 2002-250. This Court rejects
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