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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 redetermination
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