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petitioner’s receipt of the $270 in 2002. Therefore, this Court
finds petitioner received $270 of income from the Hawaii Public
Employees Health Fund in 2002.
Petitioner also asserted he was not liable for the
deficiencies, making tax-protester arguments including: (1) He
is not a taxpayer; (2) respondent has no jurisdiction over him;
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., Wetzel v. Commissioner, T.C. Memo.
2005-211 (rejecting as frivolous the argument that the taxpayer
was not a taxpayer); Nunn v. Commissioner, T.C. Memo. 2002-250
(rejecting as without merit the argument that the Commissioner
had no jurisdiction over the taxpayer or his documents). This
Court rejects petitioner’s tax-protester arguments as frivolous
and without merit.
Respondent determined that petitioner is liable for
additions to tax under section 6651(a)(1) for failure to file an
income tax return for 2002 and under section 6654(a) for failure
to make estimated tax payments for 2002. Respondent bears the
burden of production with respect to petitioner’s liability for
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