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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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