- 8 - issue. Unfortunately, petitioner failed to respond to the Court's order as directed. If petitioner did not receive the income determined by respondent, petitioner could have easily so alleged. We see no need to catalog petitioner's various arguments and painstakingly address them. As the Court of Appeals for the Fifth Circuit has remarked: "We perceive no need to refute these arguments with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit." Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984). Suffice it to say that "It is within the undoubted power of Congress to provide any reasonable system for the collection of taxes * * * if only the injunction against the taking of property without due process of law in the method of collection and protection of the taxpayer is satisfied." Wickwire v. Reinecke, 275 U.S. 101, 105-106 (1927); see Goss v. Lopez, 419 U.S. 565 (1975). The deficiency procedures set forth in subchapter B of chapter 63 of the Internal Revenue Code (secs. 6211-6215), which specifically provide for the issuance of notices of deficiency and the prepayment review of such notices by this Court, satisfy the "due process" standard of the 5th Amendment. See Adler v. Commissioner, T.C. Memo. 1989-446, affd. without published opinion 930 F.2d 26 (9th Cir. 1991); see also Olshausen v. Commissioner, 273 F.2d 23 (9th Cir. 1959), affg. andPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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