- 4 - for its authority" to assess and collect taxes if a Tax Court petition was not filed. By subsequent order, this Court advised petitioner that his grounds for refusing to stipulate or admit lacked merit and further directed him to file supplemental responses to the show cause order and the motion to review that specifically addressed each factual matter raised by respondent. Petitioner was further advised that any failure to respond as directed could result in matters being deemed stipulated or admitted. The Court also set a hearing to review petitioner's responses at the commencement of the trial calendar in Houston, Texas, on June 10, 1996. Petitioner's supplemental responses failed to specifically address any matter in the proposed stipulations or the requests for admission. Instead, in terms substantially identical to those previously rejected by the Court, petitioner repeated the BATF argument, and expanded on the argument regarding the lack of implementing regulations, claiming that title 27 of the Code of Federal Regulations, but not title 26 thereof, contains implementing regulations for Internal Revenue Code sections concerned with the assessment and collection of taxes. Thus, petitioner concluded, the absence of regulations in title 26 of the Code of Federal Regulations precludes respondent from enforcing such Internal Revenue Code sections. At the June 10, 1996, hearing to review petitioner's responses, petitioner renewed his argument regarding the lack of implementing regulations and orally moved for dismissal. InPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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