- 4 - second amended petition setting forth with specificity each error allegedly made by respondent in the determination of the deficiencies and separate statements of every fact upon which the assignments of error are based. Petitioner timely filed his second amended petition with the Court. In addition to allegations virtually identical to those in his amended petition, petitioner added the following in his second amended petition: 5. The facts upon which the petitioner relies, as the basis of petitioner's case, are as follows: a. The alleged Notice of Deficiency is not a true and/or proper Notice of Deficiency. Agency entries made in the administration of petitioner's tax account are to be posted to the Internal Revenue system of records Treasury/IRS 24.030, Individual Master File, with transaction code 494. b. No transaction code 494, indicating that a true and/or property Notice of Deficiency has be [sic] sent to the petitioner, has been posted to the petitioner's Individual Master File. c. The petitioner requested an administrative hearing with an Internal Revenue Appeals Officer in accordance with the Commissioner's instructions published in the Internal Revenue Manual. d. The Internal Revenue Manual was promulgated in accordance with 26 U.S.C. 7801, 7802, and 7805[.] e. The petitioner was charged with an excise tax violation, a non-master file tax, as indicated on his non-master file transcript. The petitioner is not involved in any activities resulting in excise tax liabilities.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011