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All section references are to the Internal Revenue Code in
effect for the years in issue. All monetary amounts have been
rounded to the nearest dollar.
Background
Petitioner filed a pro se petition using a form that had
obviously been prepared by someone else. Petitioner disputed
respondent's determinations, but he failed to allege any facts in
support of his position. Petitioner attached to his petition
Exhibit "A", stating as follows:
EXHIBIT "A"
DEMAND IS MADE THAT THE TAX COURT TRANSFER THIS CASE TO
THE APPELLATE DIVISION OF THE IRS ON THE GROUNDS THAT
THIS TAXPAYER HAS BEEN DENIED DUE PROCESS OF LAW, AND
HAS A SUBSTANTIAL CLAIM UNDER THE "NEW" TAXPAYER BILL
OF RIGHTS, AGAINST THE AGENT AND THE IRS, PLUS OTHER
CAUSES OF ACTION THAT HAVE NOT BEEN FULLY DETERMINED AS
OF THE PRESENT DATE.
AVOIDANCE AND/OR AFFIRMATIVE DEFENSES
PETITIONER ALLEGES AS AN AVOIDANCE AND/OR AFFIRMATIVE
DEFENSE EACH OF THE FOLLOWING THAT HAVE BEEN MARKED BY
AN "X" ON THE LINE BEFORE THE ITEM LISTED:
X RES JUDICATA
X ESTOPPEL
X WAIVER
X DURESS
X FRAUD
X STATUTE OF LIMITATIONS
X INVALID NOTICE OF DEFICIENCY NOT COMPLYING
WITH THE TAX CODE PROVISIONS
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Last modified: May 25, 2011