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that petitioner received the notice of deficiency dated November
5, 1999, and disregarded the opportunity to file a petition for
redetermination with this Court. See sec. 6213(a). Under the
circumstances, section 6330(c)(2)(B) bars petitioner from
challenging the existence or the amount of his underlying tax
liability for 1997 in this collection review proceeding.
In addition to the bar imposed by section 6330(c)(2)(B),
petitioner’s argument that he is not subject to the Federal
income tax is frivolous and groundless. See Goza v.
Commissioner, supra. 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 (5th Cir.
1984). Suffice it to say that petitioner is a taxpayer who is
subject to the Federal income tax on his wages and pensions. See
secs. 1(c), 61(a)(1), (11), 7701(a)(1), (14); Nestor v.
Commissioner, 118 T.C. 162, 165 (2002).
Petitioner next argues that the Appeals officer failed to
obtain verification from the Secretary that the requirements of
all applicable laws and administrative procedures were met as
required by section 6330(c)(1). We reject petitioner’s argument
because the record establishes that the Appeals officer obtained
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