Harold E. Call - Page 15

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                    THE WITNESS:  Yes, sir.                                           
                    THE COURT:  I believe that you received those                     
               statutory notices of deficiency, and that you did not                  
               file a petition with the U.S. Tax Court within the 90                  
               day period--                                                           
                    THE WITNESS:  No, sir, I was remiss in not doing                  
               that.                                                                  
                    THE COURT:  --if you disagreed with the numbers on                
               those notices that probably or that would have been in                 
               your best interest to file that.                                       
                    THE WITNESS:  That is not what I disagreed with.                  
               It is some of the subsequent notices that I have gotten                
               and the figures don’t seem to add up.                                  
          Given these remarks, the Court is satisfied that petitioner                 
          received the statutory notices and did not timely petition this             
          Court for redetermination when he had the opportunity to do so.             
          Accordingly, petitioner is precluded under section 6330(c)(2)(B)            
          from disputing his underlying 1998 and 1999 liabilities in this             
          proceeding.  Other comments and contentions in the record                   
          generally challenging the “existence” of any statute imposing or            
          requiring him to pay income tax warrant no further comment.  See            
          Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) (“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.”).                               
                    3.  Review for Abuse of Discretion                                
               Petitioner has also made various arguments relating to                 
          aspects of the assessment and collection procedures that we                 






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