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adjustments. Petitioner was ordered to show cause why the
proposed facts in the stipulation should not be admitted as true,
whereupon petitioner made directly contradictory statements under
oath. Petitioner asserted a jurisdictional challenge to the
notices of deficiency, premised on the shopworn argument that the
notices were void because they were not issued by an authorized
individual with either statutory or delegated authority to do so.
That argument is without merit, see Nestor v. Commissioner, 118
T.C. 162, 165 (2002), and we denied that motion.
Petitioner’s intention to institute and maintain this
proceeding for delay is also indicated by his failure to file a
pretrial memorandum, as required by the Court’s pretrial order.
Moreover, at the trial, the Court ordered petitioner to file a
memorandum in support of his objections to two of respondent’s
exhibits, but petitioner failed to do so.
In sum, petitioner failed to file Federal income tax returns
for the years at issue and offered no credible justification for
that failure. He instituted a proceeding in this Court without
assigning any specific errors to respondent’s determinations. He
failed to cooperate with respondent in preparing this case for
trial, and essentially failed to produce any evidence whatsoever
to justify his blanket rejection of respondent’s deficiency
determinations. We interpret those actions as evidence of his
intent to delay this proceeding; he has also advanced frivolous
arguments. He has caused both the Court and respondent to expend
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