John O. Green - Page 5




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                                     Discussion                                       
          I.  Introduction                                                            
               Although in the petition and amended petition petitioner               
          assigns numerous errors to respondent’s determinations and makes            
          various averments in support thereof, on brief petitioner states            
          the nature of the controversy between him and respondent to be              
          the jurisdiction of the Court “on the points raised in                      
          Petitioner’s Motion to Dismiss.”  He describes the issues to be             
          decided as whether (1) “the Court has jurisdiction to decide this           
          matter” (we assume respondent’s determinations), and (2) if we              
          determine we do have jurisdiction, respondent has “lost the                 
          presumption of correctness.”  He also claims that he is not                 
          liable for the remaining additions to tax.  We shall address                
          those issues.  We deem petitioner to have abandoned any other               
          errors he assigned.  See Mendes v. Commissioner, 121 T.C. 308,              
          312-313 (2003) (“If an argument is not pursued on brief, we may             
          conclude that it has been abandoned.”).                                     
          II.  Jurisdiction                                                           
               A.  Introduction                                                       
               We have subject matter jurisdiction to redetermine a                   
          deficiency if the Commissioner has issued a valid notice of                 
          deficiency and the taxpayer has timely filed a petition.  Secs.             
          6212 and 6213; Rules 13, 20; e.g., Monge v. Commissioner, 93 T.C.           
          22, 27 (1989).  Because petitioner timely filed the petition,               







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