Anne M. Rogers - Page 3




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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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