see Tax Ct. R. 91(f)(3), Moore asserted that the income tax is unconstitutional; that the income tax applies only to public employees; that the IRS is not a federal agency; that the IRS has no power outside the District of Columbia or “federal enclaves”; and that the Paperwork Reduetion Act relieves taxpayers from the statutory requirements of filing tax returns and paying taxes. Because Moore’s response to the order to show cause is “not fairly directed to the proposed stipulation, the Tax Court properly deemed the proposed stipulation established. See Tax Ct. R. 91(f)(3). To the extent that Moore seeks in this appeal to challenge his underlying tax liability documented in the stipulation, he may not do so now. Giamelli v. Comm’r of Internal Revenue, 129 T.C. 107, 115 (2007) (<HOLDING>). The parties were limited to the
holding that the tax court does not have authority to consider section 6630c2 issues that were not raised before the appeals office holding that issues not raised before the district court cannot be raised for the first time before this court holding that we generally may not consider issues not raised before the bia holding that where it was clear that the court of appeals had limited the issues on resentencing to the one issue raised in the defendants first appeal the district court did not err in declining to consider other issues raised by the defendant on remand holding that issues not raised before the trial court cannot be raised on appeal