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T.C. Memo. 1989-664, affd. without published opinion 923 F.2d 861
(9th Cir. 1991).
Petitioner makes tax protester arguments that have been
heard by this Court on many occasions and rejected. The short
answer to petitioner's contentions is that she is not exempt from
Federal income tax. See Abrams v. Commissioner, supra at 406-
407. Furthermore, this Court generally (as in the case here)
will not look behind a deficiency notice to examine evidence used
or the propriety of the Commissioner's motives, or the
administrative policy or procedures involved in making her
determinations. Abrams v. Commissioner, supra at 406; Riland v.
Commissioner, 79 T.C. 185, 201 (1982); Greenberg's Express Inc.
v. Commissioner, 62 T.C. 324, 327 (1974).
Petitioner has failed to raise any issue with regard to the
amount of her income or deductions, or the correct amount of her
tax liability, including the additions to tax and penalty.
Accordingly, she has not raised any justiciable issues, and
respondent's motion to dismiss will be granted.
Section 6673 authorizes this Court to impose a penalty in
favor of the United States, in an amount not to exceed $25,000,
whenever it appears that the taxpayer's position in a proceeding
is frivolous, groundless, or instituted or maintained primarily
for delay. Petitioner has made frivolous arguments. In the
Court's order for an objection or amended petition, the Court
noted that wages are taxable and section 6651(a)(1) does pertain
to income tax. Petitioner was advised that the allegations in
the petition were similar to those in other cases in which
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