Michael Joseph Major - Page 11

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          respect to petitioner’s 1999 return appear to be respondent’s               
          good faith attempt to give petitioner the benefit of what                   
          appeared to be valid dependency exemptions.  Respondent’s actions           
          were not illegal or unconstitutional, and they cast no doubt on             
          the validity of the notice of deficiency for 1999.                          
               We lack jurisdiction to consider petitioner’s contentions              
          regarding his offer in compromise because our jurisdiction in               
          this case is limited to redetermining petitioner’s correct tax              
          liabilities for 1999 and 2000.                                              
               To consider petitioner’s contentions concerning a conspiracy           
          or vendetta against him, we would have to consider evidence of              
          respondent’s conduct other than that stated in the notices of               
          deficiency.  The notices directly pertain to petitioner and were            
          issued after an audit.  Petitioner has not alleged any conduct by           
          respondent sufficient to cause us to look behind the statutory              
          notices of deficiency under Greenberg’s Express, Inc. v.                    
          Commissioner, 62 T.C. 324 (1974).  We are satisfied that                    
          petitioner raises no issue warranting that we look behind the               
          statutory notices of deficiency.                                            
               Petitioner contends that Bennett v. Commissioner, T.C. Memo.           
          1997-505, created an exception to this rule when there is                   
          substantial evidence of unconstitutional conduct by the                     
          Commissioner.                                                               







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