Harold L. Perry - Page 6

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          hearing in this matter from Washington, D.C. to San Francisco, as           
          requested in petitioner's motion filed one day prior to the date            
          of the scheduled hearing, would serve no purpose but to delay the           
          resolution of respondent's motion.  Consequently, petitioner's              
          motion will be denied.                                                      
          Respondent's Motion                                                         
               Rule 34(b)(4) requires that a petition filed in this Court             
          contain clear and concise assignments of each and every error               
          that the taxpayer alleges to have been committed by the                     
          Commissioner in the determination of the deficiency and the                 
          additions to tax in dispute.  Rule 34(b)(5) further requires that           
          the petition contain clear and concise statements of the facts on           
          which the taxpayer bases the assignments of error.  See Jarvis v.           
          Commissioner, 78 T.C. 646, 658 (1982).                                      
               The petition filed in this case does not satisfy the                   
          requirements of Rule 34(b)(4) and (5).  Although petitioner                 
          states that he disagrees with respondent’s determinations, there            
          is neither assignment of error nor allegation of fact in support            
          of any assigned error.  After having been provided the                      
          opportunity to do so, petitioner failed to file a proper amended            
          petition as he was directed to by the Court.  The allegations               
          contained in the petition that petitioner has not had an                    
          opportunity to meet with respondent to discuss his 1991 Federal             
          income tax liability and that respondent has failed to respond to           

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