Thomas G. Brenner - Page 12

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          6211.  We previously have held to the contrary; i.e., the                   
          regulation is not an unreasonable interpretation of section 6211.           
          Spurlock v. Commissioner, 118 T.C. 155, 161 n.8 (2002).  In so              
          holding, we noted that the Supreme Court cited the regulation in            
          Laing v. United States, supra at 174, stating:  “Where there has            
          been no tax return filed, the deficiency is the amount of tax               
          due.”                                                                       
               Petitioner, having failed to file Federal income tax returns           
          for 1991-97, was sent a notice of deficiency by certified or                
          registered mail signed by the District Director.  The notice                
          unquestionably meets the minimum requirements; respondent                   
          properly “determined” the deficiency within the meaning of                  
          section 6212(a).  We hold that the notice of deficiency is valid.           
               We see no need to catalog petitioner’s remaining arguments,            
          covering topics ranging from communism to separation of church              
          and state, and painstakingly address them.  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).                                            
          B.   Deficiencies and Additions to Tax                                      
               1.   Deficiencies: Reconstruction of Income                            
               Taxpayers bear the responsibility to maintain books and                






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