                          T.C. Memo. 1997-573



                        UNITED STATES TAX COURT



               THOMAS W. MINGUSKE, Petitioner v.
          COMMISSIONER OF INTERNAL REVENUE, Respondent



     Docket No. 1180-96.                Filed December 29, 1997.



     Thomas W. Minguske, pro se.

     Lynn M. Brimer and Eric R. Skinner, for respondent.



             MEMORANDUM FINDINGS OF FACT AND OPINION


     LARO, Judge:   Petitioner petitioned the Court to redetermine

respondent's determinations with respect to his 1992 and 1993

Federal income taxes.    Respondent determined the following income

tax deficiencies and additions thereto:

                                 Additions to Tax
                                    Sec.       Sec.
                                - 2 -


     Year         Deficiency    6651(a)(1)     6654

     1992       $43,505        $10,376     $1,011
     1993        45,097         11,274       ---
     We must decide whether to sustain these determinations.       We

hold in respondent's favor.    Section references are to the

Internal Revenue Code in effect for the subject years.      Rule

references are to the Tax Court Rules of Practice and Procedure.

                           FINDINGS OF FACT

     Some of the facts have been stipulated.    These stipulations

and the exhibits submitted therewith are incorporated herein by

this reference.    Petitioner resided in Charlotte, Michigan, when

he petitioned the Court.

     Petitioner did not file a Federal income tax return for

either of the subject years.    During those years, petitioner was

a licensed dentist, and he operated a dental practice as a sole

proprietor.   During 1992, petitioner received the following

amounts of money for his dental services:

                    Payer                              Amount
     Delta Dental Plan of Michigan                    $79,682
     The Travelers                                      4,854
     Aetna Life Insurance Co.                           6,488
     Metropolitan Life Insurance Co.                    5,634
     SET, Inc.                                          1,664
     Blue Cross Blue Shield of Michigan                 5,537
     Prudential Insurance Co. of America                1,960
     Phoenix Home Life Mutual                             655
     Delta Dental Plan of California                    2,638
     Alexis, Inc.                                       1,957
     Spartan Motors                                     6,592
     Oxyfresh USA, Inc.                                   798
     Connecticut General Life Insurance Co.             2,104
     Continental Assurance Co.                            624
     John V. Carr & Son                                   640
                                 - 3 -


     Meijer, Inc.                                    1,190
     Michigan Employee Benefit Services                628
     Team One Chevrolet                                936
     Robert Sinto Corp.                              1,090
     United Health and Life Insurance                1,460
     Farmers Insurance Exchange                      4,374
       Total                                       131,505

In 1992, petitioner also received a $118 refund for income taxes

paid to the State of Michigan in the prior year.   Petitioner

filed a 1991 Federal income tax return.

     During 1993, petitioner received the following amounts of

money for his dental services:

                    Payer                           Amount
     Delta Dental Plan of Michigan                 $76,811
     The Travelers                                   5,114
     Aetna Life Insurance Co.                        5,699
     Metropolitan Life Insurance Co.                 2,898
     SET, Inc.                                       1,000
     Blue Cross Blue Shield of Michigan              4,726
     Prudential Insurance Co. of America             5,168
     Phoenix Home Life Mutual                        1,345
     Delta Dental Plan of California                   854
     Alexis, Inc.                                    1,161
     Spartan Motors                                  7,707
     Cigna Health Care Benefits                      2,871
     Healthcare Service Corp.                        2,901
     Group Administrators Ltd.                         758
     Michigan Mutual Insurance Co.                     925
     Lansing Community College                         715
     Blue Care Inc.                                    840
     Accident Fund of Michigan                       1,780
     American Medical Security                         879
     Fortis Benefits Insurance Co.                     952
       Total                                       125,104

In 1993, petitioner also realized bartering income of $50 from a

transaction with Trade Network, Inc.
                              - 4 -


                             OPINION

     Petitioner did not file an income tax return for either year

in issue, and respondent determined that petitioner was liable

for the above-mentioned deficiencies and additions thereto.

Petitioner must prove respondent's determinations wrong.     Rule

142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).

     Petitioner has not introduced any evidence that rebuts the

evidence submitted in support of respondent's determination of

the income tax deficiencies and additions thereto.   Instead of

attempting to challenge the merits of respondent's

determinations, petitioner chooses to rely on shopworn assertions

as to the validity of the Federal income tax system.     All of

petitioner's arguments are similar to rejected arguments of other

taxpayers who have previously petitioned this Court in protest of

their liability for Federal income tax.   Petitioner's assertions

in this case are characteristic of the tax-protester rhetoric

that has been universally rejected by this and other courts.      We

will not painstakingly address petitioner's assertions as to the

validity of the Federal income tax system "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).     Suffice it to

say that petitioner is subject to Federal income tax during the

relevant years, and we sustain respondent's determinations.
                            - 5 -


To reflect the foregoing,


                                         Decision will be entered

                                    for respondent.
