- 3 - 1997. Her employers withheld Federal income tax from petitioner’s earnings for 1995, 1996, and 1997. Petitioner did not make any estimated tax payments for 1996 or 1997. OPINION Petitioner has not presented any evidence or made any argument that she did not receive the income determined in respondent’s notice of deficiency or that she is entitled to deductions not allowed by respondent. Petitioner, like many before her, has presented a “hodgepodge of unsupported assertions, irrelevant platitudes, and legalistic gibberish”. Crain v. Commissioner, 737 F.2d 1417, 1418 (5th Cir. 1984). As the Court of Appeals stated in Crain, “We perceive no need to refute these arguments with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit.” Id. at 1417. We briefly describe those contentions that are central to her position. Validity of the Notice Petitioner contends that the notice of deficiency was not sufficient because it failed to identify the Code sections under which respondent’s determination was made. Section 7522 sets forth requirements as to the contents of notices, including a statutory notice of deficiency under section 6212. Section 7522(a) provides that the notice “shall describe the basis for, and identify the amounts (if any) of, the tax due, interest,Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011