- 4 - 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 whichPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011