-4-
in 1994. Respondent determined that petitioner's gain on the
sale of his residence was equal to the net sale price of the
property.
C. Petition
Petitioner sent a letter to the Court which was filed as an
imperfect petition because it did not comply with our Rules as to
the form and content of a petition. The Court ordered petitioner
to file an amended petition. In the amended petition, petitioner
contended that respondent erred in: (1) Determining that all of
the proceeds from the sale of petitioner's residence were capital
gain, and (2) imposing a direct tax or an indirect tax on
petitioner's income.
At a time not stated in the record after petitioner filed
the amended petition, and before trial, respondent conceded that
petitioner had an adjusted basis in the residence of $137,386,
instead of zero, as determined in the notice of deficiency.
D. Pretrial Memorandum
Petitioner submitted a pretrial memorandum in which he
listed as issues for trial: (1) Whether respondent violated
petitioner's rights of due process of law and equal protection
under the law; and (2) whether respondent deprived, took, denied,
or disparaged "petitioner of rights with mere 'policy', 'custom',
'regulation' and 'color of law', lacking enactment or enabling
clause or an appropriate court under Art. III, sec. 2."
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