Vivan D. Rodriguez - Page 4

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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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