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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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Last modified: May 25, 2011