Page:Hook v. United States.pdf/10

 liabilities for tax years 1992-1996 and 2001-2005. "Under [§ 6512(a)], filing a petition to the Tax Court to challenge an asserted deficiency bars the taxpayer from bringing a suit in any other court for the recovery of any part of the tax for that taxable year." Koss v. United States, 69 F.3d 705, 708 (3d Cir. 1995). Ms. Hook’s sole argument is that the Tax Court proceedings were constitutionally flawed and the government failed to meet its burden of proof in those cases. But neither of these circumstances are among the six exceptions to the statutory bar enumerated in § 6512(a). 10