Shirley S. Hirsh - Page 4

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               On April 8, 1996, petitioner submitted a document entitled             
          "Part One Non-Statutory Abatement", which purports to be a                  
          pleading filed in the "superior court, Hanover county, Virginia".           
          The six-page document generally denies the authority of                     
          respondent and this Court to deal with the subject matter of this           
          proceeding.  On the same date, based on the aforementioned                  
          document, respondent's Appeals officer warned petitioner that she           
          might be subject to penalties pursuant to section 6673.                     
               On July 10, 1996, respondent's counsel served discovery on             
          petitioner, including a request for production of documents and             
          other related information and interrogatories.  Petitioner did              
          not produce the requested documents and did not answer the                  
          interrogatories.                                                            
               On August 5, 1996, petitioner submitted a document entitled            
          "Addendum to Non-Statutory Abatement, Parts One and Two".  The              
          document contained tax protester-type arguments and did not                 
          respond to or explain petitioner’s failure to respond to the                
          discovery.                                                                  
               On January 13, 1997, this case was called for trial, and               
          counsel for respondent appeared and was heard.  There was no                
          formal appearance by or on behalf of petitioner when the case was           
          called.  However, petitioner on that day submitted a document               
          entitled "Notice of Demand to Withdraw Petition Known as Docket             
          No. 2657-95".  The aforementioned document is a 13-page, single-            





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