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Goza v. Commissioner, supra. Section 6330(d) provides for
judicial review of the administrative determination in the Tax
Court or a Federal District Court, as may be appropriate.
Petitioner first contends that he was denied the opportunity
to challenge the existence or amount of his tax liabilities for
the years in question. The record in this case shows otherwise.
Respondent summarily assessed the underlying taxes for 1992
to 1997 and 1999 inasmuch as petitioner reported such tax
liabilities on his tax returns. Sec. 6201(a)(1). Consequently,
respondent did not issue notices of deficiency to petitioner for
the years in question. However, during the administrative
hearing, the Appeals officer invited petitioner to show him “that
the underlying tax is incorrect”. Rather than offer proof
challenging the existence or amount of the tax liabilities,
petitioner responded by demanding that the Appeals officer cite
the statutory provision making petitioner liable for Federal
income taxes. The Appeals officer declined to do so.
The record also shows that petitioner’s position regarding
his liability for Federal income taxes is frivolous and
groundless. In particular, in his objection to respondent’s
motion, petitioner asserts: “Money that is earned while engaged
in my God given and Constitutional RIGHT to life liberty and the
pursuit of happiness is not a taxable source of income unless
apportioned by the States.” As the Court of Appeals for the
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