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Petitioner next argues that respondent acted in a quasi-
judicial manner in determining deficiencies and additions to tax
against him and that respondent did not comply with all laws
before issuing the notice of deficiency. This argument must also
fail. In general, we do not look behind the notice of
deficiency, see Greenberg’s Express, Inc. v. Commissioner, 62
T.C. 324, 327-328 (1974), and there is no reason to do so here.
Petitioner makes a vague claim that the notice of deficiency was
arbitrary or erroneous. But the notice was not arbitrary or
erroneous, since petitioner does not dispute the facts upon which
the determinations were based. See, e.g., Weimerskirch v.
Commissioner, 596 F.2d 358 (9th Cir. 1979), revg. 67 T.C. 672
(1977). Moreover, it is well established that the Commissioner
need not give a taxpayer the opportunity to appeal at the
administrative level before issuing a notice of deficiency. See
Estate of Barrett v. Commissioner, T.C. Memo. 1994-535, affd.
without published opinion 87 F.3d 1318 (9th Cir. 1996).
Next, petitioner argues that any Treasury regulation that
does not cite the statute under which the regulation was issued
is invalid. Petitioner bases this argument on a provision from
the Code of Federal Regulations, which states: “Each section in
a document subject to codification must include, or be covered
by, a complete citation of the authority under which the section
is issued”. 1 C.F.R. sec. 21.40 (1999). A “document” for this
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