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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,
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