The cases were continued from the June 8, 2015, calendar, but the Judge presiding at that calendar retained jurisdiction in order to assist the parties in preparing for a later trial, specifically in reaching a stipulation of facts. On July 8, 2015, the Judge summarized proceedings to that time and denied another frivolous motion of petitioners, explaining:

Contrary to petitioners' Motion for Sanctions, the record in these cases supports the conclusion that petitioners, not respondent,2016 Tax Ct. Memo LEXIS 140">*149 have failed to comply with this Court's Standing Pretrial Order. As that Order states, if the failure to stipulate is "due to lack of cooperation by either party, the Court may order sanctions against the uncooperative party."

On the basis of the record before us, it appears that petitioners do not intend to prosecute their cases in accordance with the Court's *150 rules, but rather insist on making frivolous arguments and impeding preparation of this case for trial. We already have warned petitioners about the consequences of making frivolous arguments (a penalty in an amount not to exceed $25,000 under section 6673). We also warn petitioners that failure to put on any evidence may result in a default or dismissal of their cases and entry of decision in favor of respondent, pursuant to Rule 123.

As we did at the June 8, 2015, hearing, we again remind petitioners that the purpose of a trial in this Court is to consider evidence of petitioners' income or deductions for the tax years 2007, 2008, 2009, 2010, 2011, and 2012 to determine their tax liability. If petitioners do not put on any such evidence, they risk being assessed tax twice on the same income should the Court sustain the notices of deficiency at2016 Tax Ct. Memo LEXIS 140">*150 issue here, as respondent, in the absence of any evidence allocating the income between them, attributed certain income to both petitioners in those notices. Furthermore, because deductions are a matter of legislative grace, petitioners must put on evidence showing that they are entitled to deductions; otherwise they may not be entitled to reduce their taxable income by those amounts.

The cases were calendared for trial on April 11, 2016. On November 17, 2015, respondent filed a motion for order to show cause why proposed facts and evidence should not be accepted as established pursuant to Rule 91(f). Attached to the proposed stipulation were over 3,500 pages of exhibits consisting of official IRS documents and petitioners' bank records. Petitioners' response was filed December 14, 2015. Petitioners did not dispute any of the specific facts set forth in respondent's proposed stipulation, and they did not raise any reasonable objection to the attached exhibits. By order dated December 16, 2015, the Court *151 made the order to show cause absolute and deemed the facts and evidence set forth in respondent's proposed stipulation to be stipulated for purposes of these cases. The order explained:

Rule 91(f)(3) provides,2016 Tax Ct. Memo LEXIS 140">*151 and petitioners were warned, that if their responses were evasive or not fairly directed to the proposed stipulation or portion thereof, that matter or portion thereof will be deemed stipulated for purposes of the pending cases. Petitioners' response consists of nonsensical denials of facts that should not reasonably be in dispute and legal arguments that are gibberish and intended only to obstruct determination of their correct liability. Petitioners' pro se status does not excuse their attempt to litter the docket of this Court with ridiculous allegations. See Parker v. Commissioner, 117 F.3d 785">117 F.3d 785, 117 F.3d 785">787 (5th Cir. 1997). Their arguments concerning delegation of authority have been rejected and characterized as frivolous. See, e.g., Winslow v. Commissioner, 139 T.C. 270">139 T.C. 270, 139 T.C. 270">274, 139 T.C. 270">276 (2012). Their arguments concerning jurisdiction, validity of the statutory notices, and legality of respondent's evidence are "frivolous squared". United States v. Cooper, 170 F.3d 691">170 F.3d 691, 170 F.3d 691">691 (7th Cir. 1999). See Hyde v. Commissioner, T.C. Memo. 2011-131; Hyde v. Commissioner, T.C. Memo. 2011-104, aff'd471 Fed. Appx. 537">471 Fed. Appx. 537 (8th Cir. 2012). They have been repeatedly warned of the adverse consequences that they face if they continue the course they have adopted in these cases.

With the exception of a few responses by Batsch to questions addressed to him by the Court, Hyde conducted the trial on behalf of petitioners. She began by stating her disagreement with the stipulation. She was advised2016 Tax Ct. Memo LEXIS 140">*152 by the Court:

The bank records should not be in dispute. This is your last opportunity to present any evidence [that] the bank deposits do not *152 represent taxable income [or] there's some nontaxable source, or that you have deductions that have not been allowed in the statutory notice. But the documents are in evidence. You may present contrary evidence, but as far as I can tell from the record, you haven't raised any reasonable dispute as to the income. * * * The only item in dispute from my perspective today is whether your failure to file tax returns was due to fraud. And as I explained yesterday, your persistence in frivolous arguments, meritless arguments, your refusal to cooperate in a correct determination of your liability is an indication that your claims are not made in good faith because you're rejecting the repeated authorities in your own case, Ms. Hyde, that the Court--the Tax Court and the Court of Appeals that your arguments are frivolous.

Notwithstanding the clear warnings to petitioners, Hyde spent over an hour presenting documents that she claimed supported her position, summarized as follows:

And let me make a couple of more comments just to get them on the record,2016 Tax Ct. Memo LEXIS 140">*153 Your Honor. And basically the point that we're getting at is we are not subject to the jurisdiction of the United States. I don't know how that's even possible. We was not born--the United States as described in the law and according to that, be it right or wrong, these laws are what we based the (inaudible) that we are not subject to. And we can't find one where we are subject to because according to this and--and according to what we are as people that is a citizen of the several states, not of what we see as being defined as the United States or the state--the term United States when you used in a geographical sense includes the state of--I mean it--it's just the--where Congress has its exclusive jurisdiction. Congress does not have exclusive jurisdiction within the States.

The factual matters addressed during her presentation were records, showing that Batsch was born in Missouri and Hyde was born in Texas, in support *153 of her theory that petitioners are not citizens of the United States for purposes of the tax laws. She also presented records that showed that petitioners' residence had been the subject of various deeds to the trust and to petitioners as trustees and is in the county2016 Tax Ct. Memo LEXIS 140">*154 of Benton rather than the city of Bentonville. Both petitioners declined to testify, asserting their privilege against self-incrimination. Thus, the only evidence in the record relating to petitioners' taxable income consists of the bank records, other documents that support Oliver's analysis, and the statutory notices. Petitioners never identified an error in Oliver's exceptionally detailed analysis of their taxable income for each year. Respondent has provided far more than the minimal evidentiary foundation to establish unreported income. See Dodge v. Commisssioner, 981 F.2d 350">981 F.2d 350 (8th Cir. 1992), aff'g in part, rev'g in part96 T.C. 172">96 T.C. 172 (1991). Once gross receipts were established, petitioners had the obligation to show offsets that would reduce taxable income. See, e.g., DiLeo v. Commissioner, 96 T.C. 858">96 T.C. 858, 96 T.C. 858">872 (1991), aff'd, 959 F.2d 16">959 F.2d 16 (2d Cir. 1992); Brooks v. Commissioner, 82 T.C. 413">82 T.C. 413, 82 T.C. 413">433 (1984), aff'd without published opinion, 772 F.2d 910">772 F.2d 910 (9th Cir. 1985).

Petitioners' failure to produce evidence with respect to the deficiencies is a ground for determination of those issues against them. Despite our reluctance to reach a decision where taxable income is duplicated to separate taxpayers, we have *154 no alternative to accepting respondent's whipsaw position. See, e.g., Putnam v. Commissioner, T.C. Memo. 2015-160, at *25-*27; Tilley v. Commissioner, T.C. Memo. 2009-83, slip op. at 12; see also Maggie Mgmt. Co. v. Commissioner, 108 T.C. 430">108 T.C. 430, 108 T.C. 430">446 (1997).

Petitioners' arguments about the validity of the section 6020(b) substitutes for returns are groundless, as Hyde was advised2016 Tax Ct. Memo LEXIS 140">*155 in Hyde v. Commissioner, T.C. Memo. 2011-104, slip op. at 5, as follows: "It is well settled that a substitute for return prepared by the Commissioner under section 6020 is prima facie 'good and sufficient for all legal purposes', including to assess Federal income tax liability shown on a substitute for return as due and owing. Seesec. 6020(b)(2); United States v. Silkman, 220 F.3d 935">220 F.3d 935, 220 F.3d 935">936 (8th Cir. 2000)." See also Rader v. Commissioner, 143 T.C. 376">143 T.C. 376, 143 T.C. 376">382 (2014); Whittington v. Commissioner, T.C. Memo. 2015-152.

Equally lacking in merit are petitioners' arguments about the validity of the statutory notices. Courts have held consistently, in various contexts, that (1) a signature is not required on a notice of deficiency and (2) provisions of the IRM do not give rights to a taxpayer or affect the validity of a notice or this Court's jurisdiction. See, e.g., Selgas v. Commissioner, 475 F.3d 697">475 F.3d 697, 475 F.3d 697">699-700 (5th Cir. 2007); Tavano v. Commissioner, 986 F.2d 1389">986 F.2d 1389, 986 F.2d 1389">1390 (11th Cir. 1993) (per *155 curiam), aff'gT.C. Memo. 1991-237; Urban v. Commissioner, 964 F.2d 888">964 F.2d 888, 964 F.2d 888">889 (9th Cir. 1992) (per curiam), aff'gT.C. Memo. 1991-220; Ball v. Commissioner, T.C. Memo. 2006-141, slip op. at 7. Arguments concerning delegation of authority have been rejected and characterized as frivolous. See, e.g., Winslow v. Commissioner, 139 T.C. 270">139 T.C. 274, 276; Roye v. Commissioner, T.C. Memo. 2012-246, at *15, *16 n.6; see also Grunsted v. Commissioner, 136 T.C. 455">136 T.C. 455, 136 T.C. 455">460-461 (2011).

Hyde has a history of pursuing frivolous arguments and rejecting the conclusions of every court that has considered them. Petitioners' theory that citizens and residents of various States are not subject to Federal jurisdiction because the applicable statutes include certain Federal territories in the statement of coverage is an argument that "includes" means "only" and excludes anything else.2016 Tax Ct. Memo LEXIS 140">*156 Such interpretative arguments have been consistently rejected in strong terms, even in judicial opinions sustaining criminal convictions. See, e.g., United States v. Ward, 833 F.2d 1538">833 F.2d 1538, 833 F.2d 1538">1539 (11th Cir. 1987) (per curiam) ("utterly without merit"); United States v. Latham, 754 F.2d 747">754 F.2d 747, 754 F.2d 747">750 (7th Cir. 1985) ("inane" and "preposterous"); United States v. Rice, 659 F.2d 524">659 F.2d 524, 659 F.2d 524">528 (5th Cir. 1981) ("frivolous non-sequitur"). The Court of Appeals for the Eighth Circuit has characterized as "absurd" an argument that taxpayers were not citizens of the *156 United States but rather citizens of a State and therefore not subject to Federal taxation. United States v. Gerads, 999 F.2d 1255">999 F.2d 1255, 999 F.2d 1255">1256 (8th Cir. 1993) (per curiam) (citing United States v. Kruger, 923 F.2d 587">923 F.2d 587, 923 F.2d 587">587-588 (8th Cir. 1991)); see Crain v. Commissioner, 737 F.2d 1417">737 F.2d 1417, 737 F.2d 1417">1418 (5th Cir. 1984) (per curiam) (granting penalties against taxpayer whose spurious arguments on taxation and jurisdiction were "unsupported" and "meritless"). No further discussion of petitioners' stale theories is warranted.

We must decide, however, whether petitioners' failure to file returns for the years before us was accompanied by an intent sufficient to sustain the section 6651(f) additions to tax. Section 6651(f) provides an increased penalty of 75% of the amount required to be shown as tax on unfiled returns if the failure to file the returns is fraudulent. In applying section 6651(f) to determine whether petitioners' failure to file tax returns was fraudulent, we consider the same elements considered in cases involving former section 6653(b) and present section 6663. See Clayton v. Commissioner, 102 T.C. 632">102 T.C. 632, 102 T.C. 632">653 (1994)2016 Tax Ct. Memo LEXIS 140">*157 ; Niedringhaus v. Commissioner, 99 T.C. 202">99 T.C. 202, 99 T.C. 202">211-213 (1992). The civil fraud penalty is a sanction provided primarily as a safeguard for the protection of the revenue and to reimburse the Government for the heavy expense of investigation and the loss resulting from the taxpayer's fraud. Helvering v. Mitchell, 303 U.S. 391">303 U.S. 391, 303 U.S. 391">401, 58 S. Ct. 630">58 S. Ct. 630, 82 L. Ed. 917">82 L. Ed. 917, 1938-1 C.B. 317*157 (1938). Respondent has the burden of proving fraud by clear and convincing evidence. Seesec. 7454(a); Rule 142(b).

Bank deposits are prima facie evidence of income. See Tokarski v. Commissioner, 87 T.C. 74">87 T.C. 74, 87 T.C. 74">77 (1986); Estate of Mason v. Commissioner, 64 T.C. 651">64 T.C. 651, 64 T.C. 651">656-657 (1975), aff'd, 566 F.2d 2">566 F.2d 2 (6th Cir. 1977). Proof of gross receipts in the amounts shown by the bank deposits analysis in these cases is sufficient to satisfy respondent's burden of showing that petitioners had an obligation to file returns. Seesecs. 1, 6011, 6012.

Fraud may be proved by circumstantial evidence, and the taxpayer's entire course of conduct may establish the requisite fraudulent intent. Rowlee v. Commissioner, 80 T.C. 1111">80 T.C. 1111, 80 T.C. 1111">1123 (1983). Circumstantial evidence of fraud includes "badges of fraud" such as those present here: a longtime pattern of failure to file returns, failure to report substantial amounts of income, failure to maintain adequate records, failure to cooperate with taxing authorities in determining the taxpayer's correct liability, and implausible or inconsistent explanations of behavior. See, e.g., Bradford v. Commissioner, 796 F.2d 303">796 F.2d 303, 796 F.2d 303">307-308 (9th Cir. 1986), aff'gT.C. Memo. 1984-601; Powell v. Granquist, 252 F.2d 56">252 F.2d 56, 252 F.2d 56">60 (9th Cir. 1958); Grosshandler v. Commissioner, 75 T.C. 1">75 T.C. 1, 75 T.C. 1">19-20 (1980)*158 ; Gajewski v. Commissioner, 67 T.C. 181">67 T.C. 181, 67 T.C. 181">199-201 (1976), aff'd without published opinion, 578 F.2d 1383">578 F.2d 1383 (8th Cir. 1978).

The additions to tax for fraud have frequently been imposed on taxpayers like petitioners "who were knowledgeable about their taxpaying responsibilities * * * [and] consciously decided to unilaterally opt out of our system of taxation." Miller v. Commissioner, 94 T.C. 316">94 T.C. 316, 94 T.C. 316">335 (1990); see Niedringhaus v. Commissioner, 99 T.C. 202">99 T.C. 212, 217-219; Porter v. Commissioner, T.C. Memo. 2015-122, at *24; Bennett v. Commissioner, T.C. Memo. 2014-256, at *12; Chase v. Commissioner, T.C. Memo. 2004-142, slip op. at 10; Madge v. Commissioner, T.C. Memo. 2000-370, slip op. at 4-5, aff'd, 23 F. App'x 604 (8th Cir. 2001). Because petitioners refused to testify, they have shown no plausible nonfraudulent2016 Tax Ct. Memo LEXIS 140">*158 explanation for their behavior. Their arguments about the validity of the statutory notices are directed at events occurring after the years in issue and do not reflect the relevant state of mind at the times the returns were due. Petitioners' persistence in discredited arguments in the face of unanimous rulings by the courts negates good faith. Thus, they have offered no defense to the inference of fraudulent intent to be drawn from the circumstantial evidence and objective facts found. Respondent's burden of proof has been satisfied.

*159 To reflect the foregoing,

Decisions will be entered for respondent.