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in writing to his frivolous and improper questions.
Petitioner’s contention that Scar v. Commissioner, 814 F.2d
1363 (9th Cir. 1987), supports his argument is dead wrong.
Petitioner’s argument that the notice of deficiency is invalid
because respondent did not make additional efforts to verify
petitioner’s claimed deductions after petitioner refused to
substantiate them is frivolous and groundless within the meaning
of section 6673(a)(1)(B).
The “Agency” Issue
Petitioner has devoted 3 pages of his 12-page reply brief to
arguing that the Internal Revenue Service is not an “agency of
the United States”. Presumably, petitioner intends by this
argument to suggest that respondent has no authority to determine
or collect petitioner’s income tax deficiencies.
In support of his argument, petitioner quotes a footnote
from the Supreme Court’s opinion in Chrysler Corp. v. Brown, 441
U.S. at 297 n.23 (1979), a single page of an answer to a
complaint allegedly filed by the United States in an Idaho
District Court case entitled Diversified Metal Prods., Inc. v. T-
Bow Co. Trust, 78 AFTR 2d 5830, 96-2 USTC par. 50,437 (D. Idaho
1996), citing at note 3 Blackmar v. Guerre, 342 U.S. 512, 514
(1952).
Petitioner’s argument is tax protester gibberish. It’s bad
enough when ignorant and gullible or disingenuous taxpayers utter
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