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In addition to the bar imposed by section 6330(c)(2)(B),
petitioner’s arguments that he is not liable for Federal income
tax and that he did not receive amounts taxable as income during
1995 are frivolous and groundless. Goza v. Commissioner, supra.
Petitioner asserts that respondent failed to identify the
statutory provisions: (1) Making petitioner liable for Federal
income tax; (2) authorizing respondent’s agents to enforce the
Internal Revenue Code; and (3) permitting respondent to file a
Notice of Federal Tax Lien. Petitioner also maintains that
respondent erroneously determined that petitioner earned “foreign
source” income during 1995 and respondent failed to identify the
specific source of such income. As the Court of Appeals for the
Fifth Circuit has remarked: "We perceive no need to refute these
arguments with somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit." Crain v. Commissioner, 737 F.2d 1417, 1417
(5th Cir. 1984).
Petitioner next asserts that respondent cannot proceed with
collection on the ground that the Notice of Federal Tax Lien
filed with the Washoe County Recorder in Reno, Nevada, was not
certified as required under Nev. Rev. Stat. Ann. sec. 108.829
(Michie 2001).4 We note that the Notice of Federal Tax Lien in
4 Nev. Rev. Stat. Ann. sec. 108.829 (Michie 2001) provides
in pertinent part:
(continued...)
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