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has listed 13 broad contentions3 which he believes support his
assertion that there has been an abuse of discretion.
Petitioner, however, in this shotgunlike approach has not
provided meaningful detail or legal support for his contentions,
either to respondent or to the Court.4
Petitioner vigorously pursued respondent’s determination of
his 1991 income tax deficiency, and he was unsuccessful in this
Court and in his Appeal to the Court of Appeals for the Fifth
Circuit. Scott v. Commissioner, T.C. Memo. 1997-507, affd. 182
F.3d 915 (5th Cir. 1999). Accordingly, petitioner may not
contest the existence or amount of the underlying tax liability
because he received a notice of deficiency, and he had a full
opportunity to dispute the underlying tax liability. Sec.
3 The broad contentions include:
(1) Appropriateness of collection actions; (2)
collection alternatives; (3) impairment of
spouse’s rights; (4) amount of tax; (5) amount of
interest; (6) amount of penalty; (7) adequacy of
notice; (8) due process rights; (9) equal
protection rights; (10) other points to be made at
hearing; (11) adequacy of Appeals rights; (12)
timeliness of notice of lien; and (13) improper
filing of lien.
4 Petitioner’s pleading, submissions to respondent, and
his legal briefs filed with the Court are terse and contain
broad platitudes without meaningful rationale or support in
statutes, regulations or case precedent. We do not hold
petitioner to a higher standard because of his extensive
legal career, but simply note that he had the ability or
capacity to provide the Court with legal support, if any
exists, for his allegations or assertions.
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Last modified: November 10, 2007