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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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