William Santangelo - Page 10

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               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).                                                                 
               Neither the petition nor the amended petition filed in this            
          case satisfies 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 passages from the petition and the amendment to amended                 
          petition previously quoted.  See 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).                                                                      
               The Court's order dated July 19, 1995, provided petitioner             
          with an opportunity to assign error and allege specific facts               
          concerning his liability for the taxable years in issue.                    
          Unfortunately, petitioner failed to properly respond to the                 
          Court's order.  Rather, petitioner elected to continue to proceed           
          with time-worn tax protester rhetoric.  See Abrams v.                       






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