- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011