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petitioner are, as will be further discussed below, of a nature
previously rejected by this and other courts. The record
therefore does not indicate that any purpose would be served by
remand or additional proceedings. The Court concludes that all
pertinent issues relating to the propriety of the collection
determination can be decided through review of the materials
before it.
2. Review of Underlying Liabilities
Statutory notices of deficiency for 1999 and 2000 were
issued to petitioner, and he has at no time alleged that he did
not receive these notices. He 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 1999 and 2000 liabilities in this
proceeding. His remaining contentions 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.”)
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