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the Appeals officer’s determination. We focus on only those
arguments which are relevant to the Appeals officer’s
determination. We classify those arguments in two categories.
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 petitioner’s tax
liability and/or reviewed the validity of it.
As to the first category, the record shows that petitioner
has received a notice of deficiency for 1994, 1995, and 1996, and
that he had an opportunity to dispute in this Court respondent’s
determination set forth in that notice. He 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). We reject this first category of arguments as untimely
and advanced improperly. Petitioner is precluded from disputing
his underlying tax liability in this proceeding. Sego v.
Commissioner, supra.
As to the second category of arguments, pertaining to
respondent’s procedures, each of these arguments is frivolous and
has been previously rejected by this Court. E.g., Bartschi v.
Commissioner, T.C. Memo. 2002-268 (and cases cited therein);
Tolotti v. Commissioner, T.C. Memo. 2002-86. Petitioner argues
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