Ruth R. Johnson-Straub - Page 5

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          Court directed petitioner to file a proper amended petition                 
          setting forth with specificity each error allegedly made by                 
          respondent in the determination of the deficiency and separate              
          statements of every fact upon which the assignments of error are            
          based.  Petitioner failed to respond to the Court's order as                
          Respondent's motion to dismiss was called for hearing                       
          pursuant to notice in Washington, D.C., on March 6, 1996.                   
          Counsel for respondent appeared at the hearing and presented                
          argument on the pending motion.  Petitioner did not appear at the           
          hearing.  However, she did file a Rule 50(c) statement with the             
          Court shortly before the hearing.3                                          
               In her Rule 50(c) statement, petitioner again reiterated her           
          claim that her rights have been violated by the issuance of the             
          notices of deficiency.  Thus, petitioner's Rule 50(c) statement             
          includes the following statements:                                          
               in preparing notices of deficiency, respondent caused a                
               collateral estoppel and/or res judicata in violation of                
               petitioner's constitutional right of due process;                      
               respondent is attempting to extort monies from                         
               petitioner utilizing the notices of deficiency in                      
               violation of law and Petitioner's constitutional right                 
               to due process of law; notices of deficiency contain                   
               penalties in violation of petitioner's constitutional                  

          3 Petitioner did not sign the Rule 50(c) statement.  We find                
          this curious, given that petitioner attempts to raise a                     
          constitutional issue out of the alleged "failure" of respondent's           
          Service Center director to sign the notices of deficiency.                  
          However, the fact of the matter is that the copy of each such               
          notice that is attached as an exhibit to the petition bears such            

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