James Vernon Williams - Page 15

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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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