Laurel Ann Curtis - Page 4

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          of trial pending U.S. District Court decision on petitioner’s               
          motion to quash 90-day deficiency notice.  All of those motions             
          were denied.                                                                
               At the trial in this case, petitioner offered no stipulation           
          of any agreed facts, nor did she offer any stipulated exhibits.             
          She offered no other documentary evidence.  She testified on her            
          own behalf, but she did not rebut the adjustments giving rise to            
          respondent’s determinations of deficiencies in tax.  The                    
          substance of her testimony was an argument that the Government              
          has no authority to tax her income and that the Court has no                
          authority to decide this case.  Indeed, petitioner testified that           
          she had stated to respondent’s counsel in this case that she                
          would “pay every dime, anything you say, if you [respondent’s               
          counsel] will show me in the tax code what section makes me                 
          liable for an income tax.”  Petitioner concedes that she has                
          failed to file returns for the years in question or make any                
          payments of tax.                                                            
               Subsequent to the trial of this case, petitioner moved for             
          sanctions, pursuant to rule 11 of the Federal Rules of Civil                
          Procedure, against respondent.  We denied that motion.                      
          I.  Deficiencies In Tax                                                     
               A.  Adjustments In Issue                                               
               Rule 34(b) deals with the content of petitions in deficiency           
          actions.  Subdivision (8) of Rule 34(b) requires that a copy of             

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