Angela Matthews - Page 5

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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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