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U.S. 41, 45-46 (1957); Price v. Moody, 677 F.2d 676, 677 (8th
Cir. 1982).
Rule 34(b)(4) requires that a petition filed in this Court
contain clear and concise assignments of each and every error
which the taxpayer alleges to have been committed by the
Commissioner in the determination of the deficiency in dispute.
Rule 34(b)(5) further requires that the petition contain clear
and concise lettered statements of the facts on which the
taxpayer bases the assignments of error. See 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, 78
T.C. 646, 658 n.19 (1982); Gordon v. Commissioner, 73 T.C. 736,
739 (1980).
The petition filed in this case does 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. Rather, there is nothing but tax protester
rhetoric and legalistic gibberish, as demonstrated by the
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