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protest of the Federal tax laws. While all of Mr. Ray's
arguments do not require responses or copious citation of
precedent (Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984),
affg. per curiam an order of this Court), we shall, nevertheless,
briefly discuss some of the issues raised.
We first address the issue of the validity of the notices of
deficiency. Section 6212 provides that "If the Secretary
determines that there is a deficiency in respect of any tax
imposed by subtitle A or B * * *, he is authorized to send notice
of such deficiency to the taxpayer by certified mail or
registered mail." Sec. 6212(a). We have construed this
statutory language broadly so as to give great latitude to the
IRS in making determinations of tax liability. See Giddio v.
Commissioner, 54 T.C. 1530, 1533 (1970).
The failure of a taxpayer to file a return does not prevent
the Commissioner from determining a deficiency. In Hartman v.
Commissioner, 65 T.C. 542, 546 (1975), we stated: "Obviously,
the fact that petitioner failed to file a return will not
insulate him from a determination by the Commissioner that a tax
is due and owing and a civil proceeding based thereon."
According to the U.S. Supreme Court, "Where there has been no tax
return filed, the deficiency is the amount of tax due." Laing v.
United States, 423 U.S. 161, 174 (1976). The argument petitioner
has advanced is inconsequential given the clear weight of
authority on this issue.
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