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a petition to conform with the requirements set forth in Rule 34
may be grounds for dismissal. Rules 34(a)(1); 123(b).
In general, the determinations made by the Commissioner in a
notice of deficiency are presumed to be correct, and the taxpayer
bears the burden of proving that those determinations are
erroneous. Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S.
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 but tax protester
rhetoric and legalistic gibberish. 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). Further, petitioner did not file an amended
petition, much less a proper amended petition, as directed by the
Court in its Order dated February 20, 1996. Rather, he filed yet
another document replete with nothing other than additional tax
protester rhetoric.
We see no need to catalog petitioner's contentions and
painstakingly address them. We have dealt with many of them
before. E.g., Devon v. Commissioner, T.C. Memo. 1995-206.
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