- 12 -
respect to the deficiencies and additions to tax here at issue.
For the same reasons, neither the Code of Federal Regulations nor
the parallel table of authorities cited by petitioner supports
his BATF transfer argument.10 We see no reason to belabor that
point.
As to petitioner's argument concerning a lack of
implementing regulations, petitioner's contention that title 27,
but not title 26, of the Code of Federal Regulations contains
implementing regulations for various Internal Revenue Code
sections,11 including those sections contained in chapters 63 and
64 regarding assessment and collection, is incorrect as a matter
of fact. Numerous regulations have been promulgated concerning
respondent's assessment and collection authority as it may bear
on these proceedings. See, e.g., secs. 301.6020-1, 301.6201-1,
301.6203-1, 301.6211-1, 301.6212-1, 301.6213-1, 301.6215-1,
301.6301-1, 301.6303-1, 301.6601-1, 301.6651-1, Proced. & Admin.
Regs. Petitioner's challenge to respondent's assessment and
collection authority has no merit. Respondent validly issued a
notice of deficiency under the authority of sections 6211 and
6212. Petitioner has invoked the jurisdiction of this Court
10 The parallel table of authorities is merely an ancillary
finding device included in the Code of Federal Regulations.
11 Petitioner cites the following Internal Revenue Code
secs.: 6020, 6201, 6203, 6301, 6303, 6321, 6331 through 6343,
6601, 6602, 6651, 6701, and 7207. Secs. 6321, 6331-6343, 6701,
and 7207 relate to issues that are not, in any conceivable way,
raised in these proceedings. We see no need to address those
provisions.
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