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constituted a deliberate refusal of delivery and repudiation
of his opportunity to contest the liability determined in
the notice of deficiency. The provisions in section
6330(c)(2)(B) limiting in collection due process cases the
right to contest the underlying tax liability are clearly
designed to prevent the creation of a prepayment remedy in
cases like this one. The validity of the underlying tax
liability therefore cannot be properly raised by petition in
this case.
We will not spend time discussing petitioner’s Cross-
Motion to Dismiss on the grounds that the Tax Court lacks
jurisdiction “to address the particular notice of deficiency
upon which this Docket is based.” In his motion, petitioner
continues on for pages making spurious and ridiculous
arguments in support of his motion. We will not waste our
time addressing them as they are meritless, timeworn
protester arguments that have been rejected and discredited
by this Court and the other Federal courts. For this
reason, petitioner’s motion will be denied.
Respondent’s Motion for Summary Judgment filed on
August 11, 2005, will be granted and respondent’s
administrative determination to proceed with collection
against petitioner will be sustained. Petitioner’s Motion
to Dismiss filed on November 14, 2005, will be denied.
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