- 7 - review the notice of determination for abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000). Petitioner argues that, prior to the issuance of the notice of deficiency, he was improperly denied his Sixth Amendment right to “confront and cross-examine” the parties who provided respondent with petitioner’s bank records. Further, petitioner argues that, prior to the issuance of the notice of deficiency, respondent improperly refused to apply for technical advice on the Sixth Amendment issue. Petitioner concludes that “The assessments for each of the tax years in question were made and a notice of deficiency issued in violation of Taxpayer’s due process rights”. While petitioner characterizes his arguments otherwise, these arguments are challenges to the notice of deficiency and the underlying tax liability. Because he received a notice of deficiency but did not petition the Court, petitioner is precluded as a matter of law from challenging the validity of the underlying tax liability. See Sego v. Commissioner, supra at 610; Goza v. Commissioner, supra at 181-182; see also sec. 6330(c)(2)(B). Even if petitioner’s arguments could be properly characterized as something other than a challenge to the underlying tax liability, we find that petitioner’s arguments are frivolous and groundless. “We perceive no need to refute these arguments with somber reasoning and copious citation ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007