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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 to
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