Craig A. Bratcher - Page 10

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          that the taxpayer alleges to have been committed by the                     
          Commissioner in the determination of the deficiency and any                 
          addition to tax in dispute.  Rule 34(b)(5) further requires that            
          the petition contain clear and concise lettered statements of the           
          facts on which the taxpayer bases the assignments of error.  See            
          Jarvis v. Commissioner, 78 T.C. 646, 658 (1982).  The failure of            
          a petition to conform with the requirements set forth in Rule 34            
          may be grounds for dismissal.  Rules 34(a)(1); 123(b).                      
               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,              
          supra at 658 n.19; Gordon v. Commissioner, 73 T.C. 736, 739                 
          (1980).                                                                     
               The petition, amended petition, and the second amended                 
          petition filed in this case do not satisfy 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 petitioner's                
          pleadings and other documents that were previously quoted.  See             
          Abrams v. Commissioner, 82 T.C. 403 (1984); Rowlee v.                       






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