- 8 - Petitioner’s motion gives the Court no reason to conclude that the subject tax was not properly assessed. It simply disregards both the statement in the notice of determination that the assessment is valid and the transcript attached to the Declaration of the Appeals officer that shows that the subject tax was assessed. Petitioner’s motion makes three other frivolous arguments. The motion states: “that withholding has nothing to do with income taxes and/or the 16th Amendment”; that “corporations only pay income taxes on their profit; this must also apply to individuals”; and that “no law makes anyone ‘liable’ for income taxes and no law required them ‘to pay’ income taxes and they have no income in the ‘constitutional sense’.” We reject these arguments as patently spurious. See, e.g., Jacobs v. Commissioner, 100 Fed. Appx. 126 (3d Cir. 2004) (per curiam). Finally, we note that petitioner has failed to assign error to any of the additions to tax determined by respondent in the notice of deficiency. Accordingly, petitioner is deemed to have conceded the additions to tax determined by respondent. See Swain v. Commissioner, 118 T.C. 358, 363 (2002). On the basis of our review of the entire record in this case, we find no abuse of discretion in respondent’s determination to proceed with collection with respect toPage: Previous 1 2 3 4 5 6 7 8 9 Next
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