- 8 - challenge the correctness of the amounts of income which he reported on his 1992 and 1993 tax returns, there is no genuine issue as to the amounts of petitioner’s underlying tax liability for 1992 and/or 1993. Petitioner advanced shopworn arguments characteristic of tax-protester rhetoric that has been universally rejected by this and other courts. Wilcox v. Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo. 1987-225; Carter v. Commissioner, 784 F.2d 1006, 1009 (9th Cir. 1986). We shall not painstakingly address petitioner’s assertions “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). 2. 1994 and 1996 The notices of deficiency for 1994 and 1996 were sent via certified mail to petitioner’s post office box, the address petitioner used on his returns and in his petition. These notices of deficiency were not returned as undeliverable. Respondent submitted a certified mailing list to confirm these facts. Accordingly, in the absence of any evidence or argument by petitioner to the contrary, petitioner is deemed to have received these notices of deficiency. Sego v. Commissioner, supra at 610-611. Petitioner chose not to file a petition for redeterminationPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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