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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.
Discussion
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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