James E. Stafford - Page 3

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          reply to respondent's answer, but since respondent did not file a           
          motion pursuant to Rule 37(c), the affirmative allegations of               
          fraud in the answer are deemed denied.                                      
               Respondent sought to have petitioner enter into stipulations           
          of fact and also served on petitioner requests for admission with           
          respect to various matters raised in this case.  Petitioner in              
          response refused to stipulate any matter or to specifically                 
          address any of the requested admissions.                                    
               In support of his refusal either to stipulate or to admit,             
          petitioner took the position that his Tax Court petition is "null           
          and void" because respondent lacks assessment and collection                
          authority, in that such authority has been transferred from the             
          Internal Revenue Service to the Bureau of Alcohol, Tobacco, and             
          Firearms (BATF).                                                            
               The Court subsequently ordered petitioner to show cause why            
          respondent's proposed stipulations should not be accepted as                
          established, directing petitioner to specifically address the               
          factual matters raised in the proposed stipulations (show cause             
          order).  Petitioner declined to comply with the show cause order,           
          repeating the argument that respondent's assessment and                     
          collection authority had been transferred to the BATF.                      
               Respondent also filed a motion to review the sufficiency of            
          petitioner's answers to requested admissions (motion to review).            
          Petitioner's response to the motion to review again referenced              
          the BATF argument and further stated that "Respondent's Notice of           
          Deficiency did not list the statute and implementing regulations            

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