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without prejudice on April 21, 2004. Belmont v. United States,
93 AFTR 2d 2004-1992 (N.D. Ohio 2004). Petitioner timely mailed
his petition to this Court on May 19, 2004, and it was filed on
May 25, 2004. See sec. 6330(d)(1); sec. 301.6330-1(f), Proced. &
Admin. Regs.
On March 27, 2006, petitioner filed with the Court a
response to the stipulation of facts, wherein he stated that he
no longer subscribed to his previous tax-protester arguments.
OPINION
Because the underlying tax liability is not at issue, this
Court’s review under section 6330 is for abuse of discretion.
See Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v.
Commissioner, 114. T.C. 176, 182 (2000). This standard requires
the Court to decide whether respondent’s determination was
arbitrary, capricious, or without sound basis in fact or law.
Woodral v. Commissioner, 112 T.C. 19, 23 (1999); Keller v.
Commissioner, T.C. Memo. 2006-166; Fowler v. Commissioner, T.C.
Memo. 2004-163.
Throughout this case, petitioner presented tax-protester
arguments, including: (1) He is not a taxpayer; (2) respondent
has no jurisdiction over him; and (3) respondent lacks authority
to assert income tax deficiencies. Petitioner’s assertions have
been rejected by this Court and other courts, and “We perceive no
need to refute these arguments with somber reasoning and copious
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