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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 statutory
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