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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. and
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