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with a trial memorandum. Petitioners enumerated seven numbered
issues in the memorandum, none of which related to the
adjustments in the notice of deficiency. The issues set forth by
petitioners related to the authority of the Internal Revenue
Service (IRS) to proceed in this matter and the jurisdiction of
this Court. Respondent's counsel advised the Court that
petitioners had failed to respond to attempted communications.
Upon a review of petitioners' trial memorandum, the Court
advised petitioner that it was incumbent upon him to address the
adjustments set forth in the notice of deficiency. The Court
explained that petitioners needed to present evidence, by way of
testimony or documents, with respect to the adjustments. The
Court further explained that petitioners would be given a limited
opportunity to present argument relating to issues set forth in
their trial memorandum and that the Court might consider imposing
a penalty under section 6673(a)(1) if petitioners pursued
arguments that were primarily for delay or were frivolous or
groundless.
A review of this record, which includes a copy of
petitioners' 1995 Federal income tax return and the notice of
deficiency dated August 27, 1997, reflects that petitioner is an
Islamic religious leader (an Imam) in the Trenton, New Jersey,
community. Petitioner asserts that he travels to places of
worship and conducts visitations on a daily basis. Petitioner
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Last modified: May 25, 2011