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A. Summary Judgment
Petitioner challenges the assessment made against him on the
ground that the notice of deficiency dated August 20, 1999, is
invalid. However, the record shows that petitioner received the
notice of deficiency and disregarded the opportunity to file a
petition for redetermination with this Court. See sec. 6213(a).
It follows that section 6330(c)(2)(B) bars petitioner from
challenging the existence or amount of his underlying tax
liability in this collection review proceeding.
Even if petitioner were permitted to challenge the validity
of the notice of deficiency, petitioner’s argument that the
notice is invalid because respondent’s Service Center director is
not properly authorized to issue notices of deficiency is
frivolous and groundless. See Nestor v. Commissioner, 118 T.C.
162, 165 (2002); Goza v. Commissioner, supra. Further, as the
Court of Appeals for the Fifth Circuit has remarked: "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." Crain v. Commissioner, 737
F.2d 1417 (5th Cir. 1984). Suffice it to say that petitioner is
a taxpayer subject to the Federal income tax, see secs. 1(a)(1),
7701(a)(1), (14), and that compensation for labor or services
rendered constitutes income subject to the Federal income tax,
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