- 5 - On October 16, 1995, the Court received a document from petitioners that was filed as petitioners' Motion for Extension of Time to File Amended Petition. The Court granted such motion, extending for a month the time within which petitioners were to file a proper amended petition and continuing for hearing respondent's pending motion to dismiss. On November 20, 1995, petitioners filed an Amended Petition alleging that "The Respondent errors in establishing a deficiency for the years 1991, 1992, and 1993." In this regard, however, we note that respondent only determined a deficiency against petitioner Rosella M. Friesen for the taxable year 1990 and against petitioner Darold D. Friesen for the taxable year 1992. Therefore, the amended petition fails to place in dispute one of the two taxable years for which deficiencies were determined and attempts to place in dispute two taxable years for which no deficiencies were determined. Apart from the foregoing, petitioners suggest in their amended petition that Federal Reserve notes are not a form of legal tender. Their argument concludes as follows: Who may legally take Federal Reserve Notes in exchange as a[n] acceptable form of payment? To this the Petitioner adds that their [sic] exist[s] no legal way for the Petitioner to satisfy the Commissioner[']s assessment at any time during this Article I presentment. Petitioners also continue to argue in their amended petition that they enjoy nonresident alien status. In this regard they argue as follows:Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011