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the Commissioner and clear and concise statements of facts upon
which the petitioner bases the assignments of error.
Furthermore, any issue not raised in the assignments of error is
deemed conceded. See id. A petition that makes only frivolous
and groundless arguments makes no justiciable claim, and it is
properly subject to a motion for judgment on the pleadings. See
Abrams v. Commissioner, 82 T.C. 403 (1984); see also Rodriguez v.
Commissioner, T.C. Memo. 1995-67 (judgment on the pleadings
granted where petitions merely set forth frivolous “protester
arguments that have been heard by this Court on many occasions
and rejected”); Wright v. Commissioner, T.C. Memo. 1990-232
(frivolous argument in petition that petitioner was exempt from
Federal taxation justified granting respondent’s motion to
dismiss for failure to state a claim); Brayton v. Commissioner,
T.C. Memo. 1989-664 (taxpayer made meritless “tax-protester”
arguments; quoting Abrams, the Court stated: “A judgment on the
pleadings is appropriate where a petition raises no justiciable
issues.”). We may grant a motion for judgment on the pleadings
as to less than all the issues in a case. See Brock v.
Commissioner, 92 T.C. 1127, 1133 (1989); Caplette v.
Commissioner, T.C. Memo. 1993-46 (partial judgment on the
pleadings, except as to fraud penalty, where petition merely
contained “tax protester arguments that have been heard and
rejected by this Court on many occasions”).
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