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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.
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Last modified: May 25, 2011