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the Commissioner but does not apply to notices of deficiency);
Janus v. Commissioner, T.C. Memo. 1996-195 (finding that forms
included in the notices of deficiency detailing the adjustments
made by the Commissioner were not substitute returns under
section 6020 and that nothing in the Internal Revenue Code
requires the Secretary to file a return pursuant to section 6020
before assessing a deficiency); Ebert v. Commissioner, T.C. Memo.
1991-629 (rejecting taxpayer's assertion that there is no section
of the Internal Revenue Code that makes taxpayer liable for the
taxes claimed), affd. without published opinion 986 F.2d 1427
(10th Cir. 1993); Rice v. Commissioner, T.C. Memo. 1978-334
(stating that the allegation that the conduct of agents of the
Internal Revenue Service in issuing the notice of deficiency
violates section 7214 is a matter over which the Tax Court has no
jurisdiction); Spencer v. Commissioner, T.C. Memo. 1977-145
(stating that section 6065 does not require notices of deficiency
issued by Commissioner to be signed under penalties of perjury).
B. Whether Petitioner Is Liable for Income Tax on the Amounts
That Terminex Paid to King of Construction in the Years in
Issue
Petitioner contends that he is not liable for tax on
payments from Terminex to King of Construction because Jesus
Christ and not petitioner owned King of Construction. We
disagree. Petitioner owned and controlled King of Construction.
There is no evidence that King of Construction is incorporated.
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