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permanent, personal, place of abode is in Arizona; he is not a
"taxpayer within the meaning of the Code"; the issuances of the
notices of deficiency to petitioner are invalid because various
delegation orders in the structure of the Treasury Department
were never promulgated in the Federal Register, and numerous
other nonsensical allegations that have absolutely no legal
merit. None of the allegations address the adjustments relating
to petitioner's income or expenses for the years at issue.
The case was calendared for trial, and, at the commencement
of the session, when the case was called from the calendar,
petitioner appeared for trial. At the conclusion of the calendar
call, the Court announced the date and time that petitioner's
case would be heard. Petitioner signed a stipulation of facts,
which he left with counsel for respondent. At the time set for
trial of the case, petitioner failed to appear to present
additional evidence. The stipulation of facts was submitted into
evidence, and the Court declared for the record that petitioner
had rested his case. Respondent offered no witnesses or other
documentary evidence, whereupon the Court declared the record of
the case closed, and the case was taken under advisement.
The determinations of respondent in a notice of deficiency
are presumed correct, and the taxpayer bears the burden of
proving that the determinations are in error. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933). The only evidence
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Last modified: May 25, 2011