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Petitioners make further allegations in the petition, which are
common in tax protester petitions, regarding the audit techniques
utilized by respondent.
In her motion to dismiss, respondent contends that the
petition fails to allege clear and concise assignments of error
in respondent's deficiency determination in violation of Rule
34(b)(4) and concise lettered statements of fact on which
petitioners base the assignments of error, in violation of Rule
34(b)(5). Attached to respondent's motion were copies of letters
sent by, or on behalf of, petitioners to respondent's agents
during the course of the investigation of their tax liabilities.
These letters contain many of the same tax protester arguments as
in the petition and petitioners' objection to respondent's motion
to dismiss.
Subsequent to the filing of respondent's motion, the Court
reviewed the petition herein and agreed with respondent that the
allegations therein are tax protester allegations that have been
repeatedly rejected by this and other courts. Accordingly,
petitioners were ordered to file an objection to respondent's
motion or, alternatively, an amended petition setting forth
adequate assignments of error and statements of fact in response
to the merits of respondent's determinations.
Petitioners filed an objection on July 24, 1996. The
objection contains further tax protester arguments including that
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