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return on the ground he “did not otherwise have an opportunity to
dispute such tax liability” within the meaning of section
6330(c)(2)(B).
We need not and do not answer this question posed by the
parties in this proceeding for the tax years 1994 and 1996.
Because petitioner failed to take advantage of any of the
numerous opportunities he was afforded to specify his alleged
losses and the years in which they occurred and to introduce
evidence in support of them, we leave the resolution of this
question to another day.
Petitioner Failed To Show His Right to Deductions
Petitioner failed to state and quantify his claims for loss
deductions in either his request for a section 6330 hearing or in
his petition to this Court. He was unable to make the Appeals
officer understand his claims for any of the years in issue, and
he failed to introduce any evidence in support of his claims at
the section 6330 hearing. Petitioner failed to file a brief in
answer to respondent’s opening brief, as he had been ordered to
do in the Court-ordered briefing schedule.11 However, we need
not reject petitioner’s contention on any of the foregoing
grounds. Cf. Aguirre v. Commissioner, 117 T.C. 324, 327 (2001).
11Petitioner’s failure to file a brief would suffice to
reject petitioner’s contention. See Rule 123; Stringer v.
Commissioner, 84 T.C. 693, 704-705 (1985), affd. 789 F.2d 917
(4th Cir. 1986); see also Petzoldt v. Commissioner, 92 T.C. 661,
603 (1989); Money v. Commissioner, 89 T.C. 46, 48 (1987).
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