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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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