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Furthermore, this Court generally (as in the case here) will
not look behind a deficiency notice to examine evidence used or
the propriety of the Commissioner's motives, or the
administrative policy or procedures involved in making her
determinations. Abrams v. Commissioner, supra at 406; Riland v.
Commissioner, 79 T.C. 185, 201 (1982); Greenberg's Express Inc.
v. Commissioner, 62 T.C. 324, 327 (1974). Petitioners'
contention that they were denied adequate notice and a meaningful
opportunity to be heard has been rejected as irrelevant numerous
times. Brock v. Commissioner, 92 T.C. 1127 (1989); Cupp v.
Commissioner, 65 T.C. 68 (1975), affd. without published opinion
559 F.2d 1207 (3d Cir. 1977); Boyce v. Commissioner, T.C. Memo.
1990-555. In addition, petitioners' contention that they have
been labeled as "tax protesters" causing them to be subjected to
"peculiar procedures" has been consistently rejected as
meritless. United States v. Amon, 669 F.2d 1351, 1356-1357 (10th
Cir. 1981); United States v. Rickman, 638 F.2d 182, 183 (10th
Cir. 1980); United States v. Scott, 521 F.2d 1188, 1195 (9th Cir.
1975).
Moreover, petitioners' contention that their case should be
heard by an Article III court and that a special trial judge
should not decide their case is without merit. The
constitutionality of the Tax Court has been repeatedly upheld on
the basis of congressional authority to create specialized courts
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