- 7 -
79, 84 (1992); 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 filed in this case does 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 other than
petitioner's allegation that respondent has violated statutory
and constitutional standards by determining deficiencies in
petitioner's income taxes based on petitioner's failure to report
wage and self-employment income, by issuing notices of
deficiencies consistent with the deficiency procedures prescribed
by law, and by advising petitioner that she has the right to
contest respondent's determination in a prepayment forum; i.e.,
this Court. Petitioner's allegation constitutes nothing other
than tax protester rhetoric and legalistic gibberish, as
demonstrated by the passages from the petition and the Rule 50(c)
statement 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 January 31, 1996, provided
petitioner with an opportunity to assign error and allege
specific facts concerning her liability for the taxable years in
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