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Discussion
Petitioner has not pointed to any specific items of income
or deductions that were not correctly determined by respondent,
and he has not shown that respondent’s determination is erroneous
as to any fact set forth in the statutory notice. Except to the
extent that concessions have been made, the record fully supports
respondent’s determination that income reported by HOMC or
allegedly belonging to Arivada is attributable to the services
provided by petitioner during the years in issue and, thus, is
taxable to him. The record also supports respondent’s
determination of the penalties under section 6662, for the
reasons stated in the opinion in T.C. Memo. 1999-381. In view of
petitioner’s failure to address these issues, we need not repeat
our discussion and resolution of the same issues addressed in the
opinion in T.C. Memo. 1999-381.
Petitioner has relied on a variety of procedural arguments.
At the time of trial, petitioner filed various motions
substantially identical to those filed by other taxpayers whose
cases were calendared for trial at the same time. See Ruocco v.
Commissioner, T.C. Memo. 2002-91. He filed a Motion to Continue
that, without any factual foundation, asserted: “Any other case,
in which the government prejudices are not present, would not
have been calendared for more than a year after the Answer was
filed.” Obviously, petitioner is not familiar with the current
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