A. Muhsin and B. Jackson Muhsin - Page 4




                                        - 4 -                                         

          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              





Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011