-4-
showing that there is a genuine issue for trial. If the * * *
[nonmoving] party does not so respond, then a decision, if
appropriate, may be entered against such party.” Rule 121(d);
accord Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986).
On the basis of the record at hand, we conclude that this
case is ripe for summary judgment in that petitioner has failed
in his response to show any genuine issue for trial. While
petitioner’s response attempts to place before the Court a
factual issue as to the existence or validity of petitioner’s
underlying tax liability for 1999, petitioner is precluded by
statute from raising that issue in this proceeding. See sec.
6330(c)(2)(B); see also Nestor v. Commissioner, 118 T.C. 162,
165-166 (2002); Michael v. Commissioner, T.C. Memo. 2003-26; Hack
v. Commissioner, T.C. Memo. 2002-243. As to petitioner’s other
arguments, all of those arguments are characteristic of shopworn
tax-protester rhetoric that has been universally rejected by this
and other courts. E.g., United States v. Hanson, 2 F.3d 942, 945
(9th Cir. 1993); Wilcox v. Commissioner, 848 F.2d 1007 (9th Cir.
1988), affg. T.C. Memo. 1987-225; Cook v. Spillman, 806 F.2d 948
(9th Cir. 1986); United States v. Studley, 783 F.2d 934, 937 (9th
Cir. 1986); Roberts v. Commissioner, 118 T.C. 365 (2002), affd.
329 F.3d 1224 (11th Cir. 2003); Nestor v. Commissioner, supra;
Davis v. Commissioner, 115 T.C. 35 (2000); Kemper v.
Commissioner, T.C. Memo. 2003-195; Hill v. Commissioner, T.C.
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