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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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