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THE WITNESS: Yes, sir.
THE COURT: I believe that you received those
statutory notices of deficiency, and that you did not
file a petition with the U.S. Tax Court within the 90
day period--
THE WITNESS: No, sir, I was remiss in not doing
that.
THE COURT: --if you disagreed with the numbers on
those notices that probably or that would have been in
your best interest to file that.
THE WITNESS: That is not what I disagreed with.
It is some of the subsequent notices that I have gotten
and the figures don’t seem to add up.
Given these remarks, the Court is satisfied that petitioner
received the statutory notices and did not timely petition this
Court for redetermination when he had the opportunity to do so.
Accordingly, petitioner is precluded under section 6330(c)(2)(B)
from disputing his underlying 1998 and 1999 liabilities in this
proceeding. Other comments and contentions in the record
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
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