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groundless statements, contentions, and arguments that petitioner
advanced in the petition.
On May 11, 2006, respondent filed a supplement to respon-
dent’s motion (respondent’s supplement). On June 12, 2006, the
Court received from petitioner a document that the Court had
filed as petitioner’s response to respondent’s motion as supple-
mented. In total disregard of the Court’s March 21, 2006 Order,
petitioner included in petitioner’s response to respondent’s
motion as supplemented certain frivolous and/or groundless
statements, contentions, and arguments that are identical to
certain frivolous and/or groundless statements, contentions, and
arguments that petitioner advanced in the petition.
Discussion
Rule 34(b) provides in pertinent part that a petition with
respect to a notice of deficiency is to contain:
(4) Clear and concise assignments of each and
every error which the petitioner alleges to have been
committed by the Commissioner in the determination of
the deficiency * * *. * * * Any issue not raised in
the assignments of error shall be deemed to be con-
ceded. * * *
(5) Clear and concise lettered statements of the
facts on which the petitioner bases the assignments of
error * * *.
The petition that petitioner filed on January 9, 2006, and
the amended petition that petitioner filed on April 7, 2006, do
not contain (1) a clear and concise statement of the errors
allegedly committed by respondent in determining the deficiency
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