Bruce M. Crow - Page 9

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          granted only if, on the facts, she is entitled to a decision as a           
          matter of law.  Zaentz v. Commissioner, 90 T.C. 753, 754 (1988).            
          On the other hand, respondent's determinations are presumed                 
          correct; the burden of proof is on petitioner to show that                  
          respondent's determinations are erroneous.  Rule 142(a); Welch v.           
          Helvering, 290 U.S. 111 (1933); Beard v. Commissioner, 82 T.C.              
          766, 773 (1984), affd. 793 F.2d 139 (6th Cir. 1986).  In                    
          addition, any issue not raised in the pleadings is deemed to be             
          conceded.  Rule 34(b); Jarvis v. Commissioner, 78 T.C. 646, 658             
          n.19 (1982); Gordon v. Commissioner, 73 T.C. 736, 739 (1980).               
               The amended petition and second amended petition filed                 
          herein contain tax protester-type legal arguments with respect to           
          the deficiencies and additions to tax and penalty determined by             
          respondent.  Petitioner does not dispute the facts underlying               
          respondent's determinations.  Moreover, all of the arguments                
          raised by petitioner have been uniformly rejected by this and               
          other courts.  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).  Unfortunately, petitioner ignored the opportunities                 
          presented to him to assign error and allege specific facts                  
          concerning his liabilities for the taxable years in issue.                  
               We see no need to catalog petitioner's contentions and                 
          painstakingly address them.  We have dealt with many of them                





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