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pursuant to Rule 50(c). In the Rule 50(c) statement, petitioner
challenged the "PERSONAM JURISDICTION" of this Court and made
further tax protester allegations, which need not be repeated
herein.
Petitioner has been here before in connection with his 1986
and 1987 tax years. Verbeck v. Commissioner, T.C. Memo. 1995-14,
affd. without published opinion 70 F.3d 122 (9th Cir. 1995). In
that case we dismissed a similar petition for failure to state a
claim and required petitioner to pay a $5,000 penalty pursuant to
section 6673. In that case and in the instant case, petitioner
made tax protester arguments that have been heard by this Court
on many occasions and rejected. See e.g., McCoy v. Commissioner,
76 T.C. 1027 (1981), affd. 696 F.2d 1234 (9th Cir. 1983); Brayton
v. Commissioner, T.C. Memo. 1989-664, affd. without published
opinion 923 F.2d 861 (9th Cir. 1991). As before, the short
answer to petitioner's arguments is that he is not exempt from
Federal income tax. See Abrams v. Commissioner, 82 T.C. 403,
406-407 (1984).
A judgment on the pleadings is appropriate where petitioner
raises no justiciable issues. See Abrams v. Commissioner, supra
at 408; Brayton v. Commissioner, supra. Petitioner has failed to
raise any issue with regard to the amount of his income or
deductions, or the correct amount of his tax liability, including
the additions to tax. Accordingly, he has not raised any
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