John S. Black - Page 7

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            Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).  The failure of                            
            a petition to conform with the requirements set forth in Rule 34                            
            may be grounds for dismissal.  Rules 34(a)(1); 123(b).                                      
                  In general, the determinations made by the Commissioner in a                          
            notice of deficiency are presumed to be correct, and the taxpayer                           
            bears the burden of proving that those determinations are                                   
            erroneous.  Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115                              
            (1933).  Moreover, any issue not raised in the pleadings is                                 
            deemed to be conceded.  Rule 34(b)(4); Jarvis v. Commissioner,                              
            supra at 658 n.19; Gordon v. Commissioner, 73 T.C. 736, 739                                 
            (1980).                                                                                     
                  The petition and amended petition filed in this case do not                           
            satisfy the requirements of Rule 34(b)(4) and (5).  There is                                
            neither assignment of error nor allegation of fact in support of                            
            any justiciable claim.  At best, petitioner's arguments amount to                           
            nothing more than tax protester rhetoric and legalistic                                     
            gibberish, as demonstrated by the passages from those documents                             
            that we have quoted above.  See Abrams v. Commissioner, 82 T.C.                             
            403 (1984); Rowlee v. Commissioner, 80 T.C. 1111 (1983); McCoy v.                           
            Commissioner, 76 T.C. 1027 (1981), affd. 696 F.2d 1234 (9th Cir.                            
            1983).                                                                                      
                  The Court's Orders dated June 28, 1995, and September 18,                             
            1995, provided petitioner with opportunities to assign error and                            
            allege specific facts concerning his liability for the taxable                              
            years in issue.  Unfortunately, petitioner failed to properly                               




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