Ruth R. Johnson-Straub - Page 8

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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            
               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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