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6651 or failure to pay estimated tax under section 6654, or that
respondent's determination relating to his itemized deductions
for 1989, 1990, and 1991 and his standard deduction for 1992, was
in error. Likewise, he did not contend in his response to
respondent's summary judgment motion that any material facts are
in dispute relating to respondent's determination. We conclude
that his objections to respondent's determinations regarding his
deductions and the additions to tax are based solely on the same
frivolous contentions on which his entire case is based.
Petitioner asserts that the District Director never notified
him that he was required to maintain books and records and file a
tax return. The District Director is not required to do so. See
sec. 6001. He also frivolously asserts that the Form 1040 is
invalid and that respondent lacked jurisdiction to issue the
notice of deficiency. In petitioner's objections to respondent's
motion for summary judgment, as supplemented, and petitioner's
motion to strike respondent's motion, petitioner claims he is not
a protester; however, his contentions are merely a rehash of
familiar tax protester arguments. See Wilcox v. Commissioner,
848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo. 1987-225; United
States v. Romero, 640 F.2d 1014 (9th Cir. 1981).
Petitioner has not alleged any facts fairly related to
respondent's determinations, and he has not raised any issue that
could possibly be affected by a hearing. See Knighten v.
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