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At the time the petition was filed in docket No. 18510-99,
petitioners David R. and Darlene Funk resided at Rocklin,
California. At the time of filing the petitions in docket Nos.
through 1366-00 through 1371-00, the officer of the trustee of
the respective trusts, Richard Marks, resided at Rocklin,
California.
Respondent asserts in his motions that each of the
respective dockets should be dismissed for failure to state a
claim on the basis that petitioners have failed to allege in the
respective petitions or amended petitions any justiciable error
and that they merely assert frivolous arguments as a protest
against paying taxes.
Paragraph 4 of the petition in each of these cases contained
as a basis for disagreement with the notice of deficiency
identical language as follows:
The District Director issued a Statutory Notice of
Deficiency claiming petitioner has a tax liability
without there being a statutorily procedural correct
lawful tax assessment. Attached to the Notice of
Deficiency, IRS Form 4549A, income tax examination
changes, line 11 states, “Total Corrected Tax
Liability.” Respondent has failed to provide the
petitioners with internal revenue code sections or
regulations this total corrected tax liability was
calculated or assessed under. The respondent has
refused to provide the petitioners with a Summary
Record of Assessment as per Internal Revenue Regulation
301.6203-1. Respondent has failed to properly sign the
Notice of Deficiency as required under IRC Section
2(...continued)
deductions.
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Last modified: May 25, 2011