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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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