Arlie G. Curry, Jr. - Page 3

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               For clarity and convenience, our findings of fact and                  
          opinion have been combined.                                                 
              After receiving the statutory notice of deficiency in this             
          case, petitioner sent a letter to the Court requesting                      
          information.  This letter was filed as a petition.  The Court               
          ordered petitioner to file an amended petition, and he did so.              
          In his amended petition, petitioner stated that he "disagrees               
          with the tax deficiencies for the years 1990 and 1991 as set                
          forth in the alleged NOTICE OF DEFICIENCY dated January 27, 1994,           
          a copy of which is attached and identified as EXHIBIT A."                   
          Petitioner went on to state:                                                
               4.   Petitioner denies all deficiencies and all                        
                    addition [sic] to the alleged tax:                                
                    a.   The alleged Notice of Deficiency issued is                   
                         not a true and/or proper Notice of                           
                         Deficiency.                                                  
                    b.   There are no math errors.                                    
                    c.   I have no liability for a non-master file                    
                         tax.                                                         
                    d.   I am not a non-resident alien, foreign                       
                         corporation, foreign partnership, or foreign                 
                         estate or trust.                                             
               Respondent subsequently filed a Motion To Dismiss For                  
          Failure To State A Claim Upon Which Relief Can Be Granted                   
          pursuant to Rule 40.  Thereafter, the Court issued an order                 
          calendaring respondent's motion for hearing, and also directing             
          petitioner to file a proper second amended petition before the              
          hearing.  Specifically, the Court directed petitioner to file a             




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