Larry R. Johnston - Page 14

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          indicates that petitioner sent communications referencing the               
          notices, making clear that these documents were received.                   
               Hence, because petitioner received valid notices of                    
          deficiency and did not timely petition for redetermination, he is           
          precluded under section 6330(c)(2)(B) from disputing his                    
          underlying tax liabilities in this proceeding.  Any remaining               
          contentions raised during the administrative proceedings                    
          generally challenging the “existence” of any statute imposing or            
          requiring him to pay income tax warrant no further comment.  See            
          Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) (“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.”)                                
               3.  Review for Abuse of Discretion                                     
               Petitioner has also made various arguments relating to                 
          aspects of the assessment and collection procedures that we                 
          review for abuse of discretion.  Action constitutes an abuse of             
          discretion under this standard where arbitrary, capricious, or              
          without sound basis in fact or law.  Woodral v. Commissioner, 112           
          T.C. 19, 23 (1999).                                                         
               Federal tax assessments are formally recorded on a record of           
          assessment in accordance with section 6203.  The Commissioner is            
          not required to use Form 23C in making an assessment.  Roberts v.           
          Commissioner, 118 T.C. at 369-371.  Furthermore, section                    






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