James G. Gilligan - Page 8

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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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