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expenses, travel expenses, education expenses, meals and
entertainment, and similar unsubstantiated items. Respondent
also determined that petitioners had other items of income that
respondent has since conceded. Respondent determined that
petitioners’ Forms 1040 were not valid income tax returns. Thus
respondent determined the additions to tax in issue and
calculated the deficiencies using rates for married persons
filing separate returns.
In each of the petitions in these cases, filed December 12,
2000, petitioners attached approximately 150 pages of exhibits
purportedly supporting their claims that the notices of
deficiency were a continuation of “harassment, lies, and criminal
fraud” committed by various Federal employees. Summarizing their
allegations, they claim “in excess of 500 criminal violations
perpetrated against * * * [them] by more than 150 different
federal co-conspirators during the past 17 1/2 years.”
OPINION
Respondent moved to strike from the petition and to dismiss
for lack of jurisdiction the allegations constituting accusations
of criminal conduct. A hearing on respondent’s motion was held
in Phoenix, Arizona, on March 19, 2001. Respondent’s motion was
granted. At that time, Mr. Nordbrock requested that any trial be
postponed for “at least 90 days”. Petitioners were advised that
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