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ANNE M. ROGERS,
COMMISSIONER OF INTERNAL REVENUE,
UNITED STATES TAX COURT
Filed January 30, 2001
Anne M. Rogers, pro se.
M. Kathryn Bellis, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
 COHEN, JUDGE: Respondent determined deficiencies and additions to tax
in petitioner's Federal income taxes for 1996 and 1997 as follows:
Additions to Tax, I.R.C.
Unless otherwise indicated, all section references are to the Internal Revenue
Code in effect for the years in issue. Petitioner denies that she is liable
for income tax or additions to tax on her earnings as a salaried employee in
FINDINGS OF FACT
 Petitioner resided in Sugar Land, Texas, at the time that her petition
was filed. Prior to and during the years in issue, petitioner was married to
Kenneth E. Rogers. Prior to and during the years in issue, petitioner was employed
by various private employers as a systems analyst. She received income from
her employment in the amounts of $97,156 in 1994, $85,386 in 1995, $87,968
in 1996, and a total of $117,095 (from two employers) in 1997. During the years
in issue, petitioner also received other income from dividends, interest, and
proceeds from the sale of stock.
 Prior to 1994, petitioner filed Federal income tax returns. For 1994,
she submitted to the Internal Revenue Service (IRS) a Form 1040, U.S. Individual
Income Tax Return, that reported her income for that year, checked her status
as "married filing separate return", and attached a statement disclaiming
any tax liability for 1994 and asserting that she "did not engage in any
licensed occupation or activity subject to an excise tax". Petitioner
did not file an income tax return for 1995, 1996, or 1997. Her employers withheld
Federal income tax from petitioner's earnings for 1995, 1996, and 1997. Petitioner
did not make any estimated tax payments for 1996 or 1997.
 Petitioner has not presented any evidence or made any argument that she
did not receive the income determined in respondent's notice of deficiency
or that she is entitled to deductions not allowed by respondent. Petitioner,
like many before her, has presented a "hodgepodge of unsupported assertions,
irrelevant platitudes, and legalistic gibberish". Crain v. Commissioner,
737 F.2d 1417, 1418 (5th Cir. 1984). As the Court of Appeals stated in Crain, "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." Id. at 1417. We briefly describe those contentions that
are central to her position.
VALIDITY OF THE NOTICE
 Petitioner contends that the notice of deficiency was not sufficient because
it failed to identify the Code sections under which respondent's determination
was made. Section 7522 sets forth requirements as to the contents of notices,
including a statutory notice of deficiency under section 6212. Section 7522(a)
provides that the notice "shall describe the basis for, and identify the
amounts (if any) of, the tax due, interest, additional amounts, additions to
tax, and assessable penalties included in such notice. An inadequate description
under the preceding sentence shall not invalidate such notice." There
is no requirement that legal citations be included in the statutory notice
mailed to petitioner. See Jarvis v. Commissioner, 78 T.C. 646, 655-656 (1982).
The notice in this case set out the specific items of unreported income received
by petitioner and the other amounts required under section 7522. The notice
sent to petitioner is sufficient for all relevant purposes of this case.
 Petitioner also argues that she was entitled to a hearing with the IRS
Appeals Division before the notice of deficiency was sent. There is no such
requirement, and it is apparent, based on petitioner's arguments, that any
such hearing would have been futile. Similarly, we reject her request that
the case be "remanded" to the IRS for further consideration of her
PETITIONER'S INCOME TAX LIABILITY
 Petitioner makes a convoluted argument that subjecting her to the same
rate of taxes as Federal employees constitutes impermissible "disparate
tax treatment." Petitioner cites a variety of Code sections and regulatory
materials to show that public employees receive benefits from the Federal Government
that are not available to her as an employee of private industry. She argues:
Whether due to favored treatment of the Federal employee, or officer in the
statutes under Title 5 U.S.C. et seq., there exist a great legal disparity
in the economic employment benefits, privileges, or protections directly received
from the Federal Government by the Federal employee, or officer, and what the
petitioner directly receives from the Federal Government
* * *.
As a result, she argues, application of the same rates of Federal income tax
to her as are applied to Federal employees is unconstitutional. She asserts
that taxes imposed on her and used to pay benefits above and beyond wages to
Federal employees are improper takings of her income for a "private purpose" within
the meaning of various cases dealing with disparate treatment by Federal statutes
 Petitioner's argument is erroneous in several respects. First, provision
of benefits to a Federal employee in relation to his or her employment is an
expenditure of funds for a public purpose, not the private purpose of the employee.
Second, tax rates are not applied to employees by classification, whether public
or private, but to levels and categories of income. Third, even if a distinction
had been made between employees paid with Federal funds and employees paid
with private funds, such classifications, having a rational basis, do not violate
the constitutional rights of taxpayers. See, e.g., Sjoroos v. Commissioner,
81 T.C. 971, 975 (1983).
ESTIMATED TAX REQUIREMENT
 Petitioner also contends that there is no "enabling legislation" requiring
payment of estimated taxes since the repeal of former section 6015 in 1984.
Former section 6015, relating to declarations of estimated income tax by individuals,
was repealed by section 412 of the Deficit Reduction Act of 1984 (DEFRA), Pub.
L. 98- 369, 98 Stat. 792. That repeal was contemporaneous with the amendment
of section 6654 in DEFRA section 411. DEFRA sections 411 and 412, 98 Stat.
788, 792, were among the simplification provisions effectuated by consolidating
into section 6654 all rules relating to payments of estimated tax.
 Sections 6654(c) and (d), as in effect for the years in issue, set forth
the number of required installments and the amount of required installments
of estimated tax due from individuals. Section 6654(a) imposes an addition
to tax for failure to make the required payments. The addition to tax determined
by respondent by reason of petitioner's failure to make the estimated tax payments
is mandatory, with exceptions not applicable in this case. See, e.g., Grosshandler
v. Commissioner, 75 T.C. 1, 20-21 (1980).
 Finally, petitioner contends that her attempts to secure explanations
from the IRS about her arguments were reasonable cause for her failure to file
returns for the years in issue. They were not. Petitioner apparently did not
consult with an attorney or accountant or any competent tax professional before
discontinuing her prior history of filing tax returns. She cites innumerable
cases out of context, while ignoring the innumerable cases upholding the validity
of the Federal income tax and rejecting arguments by individuals that they
are not required to file Federal income tax returns and pay Federal income
taxes. Her failure to file returns for the years in issue was not due to reasonable
cause. She is liable for the addition to tax under section 6651(a) as determined
 Decision will be entered for respondent.
Return to Tax Protestor Exhibit