- 6 - subject examination of petitioner's tax liability for those years. Respondent has not made any tax assessment for those same years. OPINION In statutory notices of deficiency, respondent determined deficiencies in petitioner's Federal income tax for the years 1986 through and including 1991. Respondent also determined additions to tax under section 6651(a) for failure to file a return for each of those years, and under section 6654(a) for failure to pay estimated taxes for 1989, 1990, and 1991. Respondent's determinations as to petitioner's tax liability are presumed correct, and petitioner has the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Petitioner asserts frivolous tax protester-type arguments that essentially ask this Court to "look behind" the notices of deficiency and find them arbitrary and excessive. Petitioner argues that the notices of deficiency and the determinations therein are invalid because respondent: (1) Failed to identify the type of tax involved; (2) improperly prepared for petitioner tax returns that did not satisfy the requirements of section 6020; (3) failed to follow Internal Revenue Manual procedures and did not identify the statute or regulation relied upon in issuing the statutory notices; (4) misclassified her source of income; and (5) did not issue the notices within the statutoryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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