- 15 - 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 wePage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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