- 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. PetitionerPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011