-7-
with the USC Title 26 taxing statute that respondent
relied on to calculate any claimed Determination. (6)
Respondent claims a Determination, but has failed to
provide petitioner with any certified facts or
evidence. (7) Respondents Notice of Determination is
null and void as it is based on hearsay facts and
evidence. (8) Petitioner has been denied a meaningful
administrative hearing where certified facts or
evidence from respondent was provided. (9) Statute of
limitation for tax year 1996 has expired. (10)
Petitioners declaration, signed under penalty of
perjury, is attached and made part of this matter.
We classify petitioners’ arguments in two manners. The
first category pertains to the existence or validity of the
underlying tax liability. The second category pertains to the
procedure by which respondent has assessed petitioners’ tax
liability and/or reviewed the validity of it.
As to the first category, it is indisputable that
petitioners have received a notice of deficiency for 1996 and
that they had an opportunity to dispute in this Court
respondent’s determination set forth in that notice. They chose
not to dispute those determinations timely. See sec. 6213(a)
(notices of deficiency addressed to taxpayers inside the United
States may be challenged by those taxpayers generally by filing a
petition with this Court within 90 days after the notice of
deficiency is mailed.). As a result, we reject this first type
of argument as untimely and advanced improperly. We hold that
petitioners are precluded from disputing their underlying tax
liability in this proceeding. Sego v. Commissioner, supra.
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