T.C. Memo. 2000-200
UNITED STATES TAX COURT
PAUL MARTIN ZIMMERMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 1023-99, 1049-99, Filed June 29, 2000.
1050-99.
Paul Martin Zimmerman, pro se.
R. Craig Schneider, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: Respondent determined
deficiencies in petitioner's Federal income taxes of $6,584,
$5,777, and $8,196 for 1995, 1996, and 1997, respectively, and
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accuracy-related penalties under section 6662(a)1 of $421.80,
$36.60, and $929.20, for 1995, 1996, and 1997, respectively.
The issues for decision are: (1) Whether petitioner is
subject to Federal income tax on wages, Social Security payments,
and IRA distributions; and (2) whether part of the underpayments
of tax is attributable to negligence or disregard of rules or
regulations, or to a substantial understatement of tax.
Background
Petitioner resided in Magna, Utah, when he filed his
petitions in these consolidated cases.
Petitioner filed timely Federal income tax returns for 1995,
1996, and 1997. Petitioner attached to his returns the
appropriate Forms W-2, 1099-R, and 1099. Petitioner failed to
compute an income tax liability on any of the returns but did
attach to each of the returns for 1995 and 1996 a letter of
explanation.
In both letters petitioner states that he needs additional
information to determine his Federal income tax liability: (1)
The sum of the adjusted gross incomes less penalties on early
withdrawal of all income tax filers; (2) the total number of
income tax filers; (3) the total amount of taxes to be collected;
and (4) the names, addresses, and Social Security numbers of
1
Unless otherwise indicated, subsequent references are to
the Internal Revenue Code in effect for the years at issue.
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elected and appointed government officials claiming exemptions,
deductions, and credits and the amounts of exemptions,
deductions, and credits claimed, "so that I can evaluate its
constitutionality".
The return for 1997 lists total wages as $46,251.08 but
bears a notation on both the return and the attached Forms W-2
that the wages are "non-taxable income" from direct labor.
Respondent determined that the amounts reported on the
returns are includable in income and subject to Federal income
tax.
Discussion
At trial, petitioner presented no facts relevant to the
deficiencies and penalties determined by respondent. He insisted
on making the kinds of inaccurate, uninformed, and nonsensical
arguments usually made by persons who disagree with the Federal
income tax system and refuse to pay income tax under any
circumstances. Among other arguments, petitioner expressed his
view that the judicial branch of the United States Government has
been "bribed" and "That's why case law shouldn't be looked at
because they've gotten to the Federal court system."
As petitioner's arguments lack any rationality, seriousness,
or weight, we see no need to refute them "with somber reasoning
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and copious citation of precedent"; if we did, it might suggest
they had some merit. Crain v. Commissioner, 737 F.2d 1417 (5th
Cir. 1984).
Petitioner did not introduce any evidence to show that he is
not liable for the income tax deficiencies and accuracy-related
penalties under section 6662(a); accordingly, respondent is
sustained on these issues for all 3 years.
Decisions will be
entered for respondent.